The U.S. IRS has released an international practice unit on the Substantial Contribution Test for CFC Manufacturing Exception. The exception concerns Foreign Base Company Sales Income (FBCSI), which is income derived by a CFC in connection with a purchase or sale of personal property involving a related party in which the goods are manufactured and sold for use/consumption outside the CFC’s country of organization. Under Subpart F, a U.S. shareholder is generally required to include its pro-…