Subpart F Income
CB&H’s Bill Elliot to Participate in Contract Manufacturing Rules Webcast
Cherry, Bekaert & Holland, L.L.P. (CB&H) is pleased to announce that Bill Elliot , Firm Director of International Tax , will be participating in the Knowledge Congress webcast entitled: “Understanding the IRS New Contract Manufacturing Rules” on February 23, 2010 from 12:00 pm until 2:00 pm. The Treasury and the IRS are in the process of finalizing the laws concerning contract manufacturing arrangements as per the anti-deferral regime Subpart F . Set to take effect for tax years of foreign controlled companies beginning after June 30th, 2009, the new guidance aims to update and modernize the contract manufacturing regs under Subpart F. While the Regs are generally well received by taxpayers, there is much confusion surrounding key areas such as: retention. Read More.
New Contract Manufacturing Regulations Offer New Substantial Contribution Test
By William P. Elliott, Cherry, Bekaert & Holland, L.L.P. (CB&H) Email: belliott@cbh.com | bio Global economic expansion and globalization have led to significant changes in manufacturing over the last 40 years. Many multinational groups have extensive manufacturing networks that straddle geographic borders primarily to leverage expertise and cost efficiencies. Contract manufacturing arrangements, which generally entail the production of goods by one company under the brand or label of another company, have become a common way to manufacture products because of the flexibility and efficiencies that they afford. Use of contract manufacturing arrangements, particularly in China, has grown exponentially to the point that. Read More.