Research Problem 1. Jerry Jeff Keen, the CFO of Boots Unlimited, a Texas corporation, has come to you regarding a potential restructuring of business operations. Boots long has manufactured its western boots in plants in Texas and Oklahoma.

Recently, Boots has explored the possibility of setting up a manufacturing subsidiary in Ireland, where manufacturing profits are taxed at 12.5%. Jerry Jeff sees this as a great idea, given that the alternative is to continue all manufacturing in the United States, where profits are taxed at 21%. Boots plans to continue all of the cutting, sizing, and hand tooling of leather in its U.S. plants. This material will be shipped to Ireland for final assembly, with the finished product shipped to retail outlets all over Europe and Asia. Your initial concern is whether the income generated by the Irish subsidiary is Subpart F income. Address this issue in a research memo, along with any planning suggestions.

Partial list of research aids:

§ 954(d).

Reg. § 1.954–3(a).

Bausch & Lomb, 71 TCM 2031, T.C.Memo. 1996–57.