Which of the following income items does not represent Subpart F income if it is earned by a controlled foreign corporation in Fredonia? Purchase of inventory from the U.S. parent, followed by:
a. Sale to anyone outside Fredonia.
b. Sale to anyone inside Fredonia.
c. Sale to a related party outside Fredonia.
d. Sale to a non-related party outside Fredonia.
b
RATIONALE: If a controlled foreign corporation purchases inventory from outside its country of incorporation, sells this inventory to customers outside its country of incorporation, and there is a related party on either the supplier or customer side of the transaction, such income is foreign base company sales income and constitutes Subpart F income [§ 954(d)]. If the controlled foreign corporation is deemed to manufacture or otherwise substantially transform the inventory before its sale, the location of the customer and the existence of related parties becomes irrelevant and the income is not Subpart F income [Treas. Reg. § 1.954-3(a)(4)(i)]. In item b., the sales are within the CFC country. In all other items, the CFC purchases inventory from a related party outside the CFC country and sells to customers (related or non-related) outside the CFC country.
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