Internal Revenue Service February 28, 2008 – Federal Register Recent Federal Regulation Documents

This document contains proposed regulations that provide guidance relating to foreign base company sales income, as defined in section 954(d), in cases in which personal property sold by a controlled foreign corporation (CFC) is manufactured, produced, or constructed pursuant to a contract manufacturing arrangement or by one or more branches of the CFC. These regulations, in general, will affect CFCs and their United States shareholders. Certain portions of these proposed regulations restate changes to Sec. 1.954-3(a)(4) that were contained in former proposed regulations.