TITLE 26. INTERNAL REVENUE CODE § 954. Foreign base company income., 26 USCS § 954

Summary

(a) Foreign base company income. For purposes of section 952(a)(2) [26 USCS § 952(a)(2)], the term “foreign base company income” means for any taxable year the sum of—

(1) the foreign personal holding company income for the taxable year (determined under subsection (c) and reduced as provided in subsection (b)(5)),

(2) the foreign base company sales income for the taxable year (determined under subsection (d) and reduced as provided in subsection (b)(5)), and

(3) the foreign base company services income for the taxable year (determined under subsection (e) and reduced as provided in subsection (b)(5)).

(b) Exclusions and special rules.

(1), (2) [Repealed]

(3) De minimis, etc., rules. For purposes of subsection (a) and section 953 [26 USCS § 953]—

(A) De minimis rule. If the sum of foreign base company income (determined without regard to paragraph (5)) and the gross insurance income for the taxable year is less than the lesser of—

(i) 5 percent of gross income, or

(ii) $1,000,000,

no part of the gross ...