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IRS Chief Counsel issues memorandum on ETI exclusion for purposes of subpart F income

|Approved Changes|United States
United States

On 29 August 2012, the Official Gazette No. 621 published Government Ordinance No. 15 for amending the Tax Code. The Ordinance was enacted, with the following changes:

The Chief Counsel of the US Internal Revenue Service (IRS) has issued a memorandum that discusses the extraterritorial income (ETI) exclusion under repealed section 114(b) of the US Internal Revenue Code (IRC) for purposes of determining a US taxpayer's subpart F income inclusions under IRC section 951(a)(1)(A)(i).…

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