Whirlpool Appellate Decision: A new standard for subpart F?
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC Value Chain Transformation Specialist Tom Quinn. They discuss the Sixth Circuit Court of Appeals ruling to uphold the US Tax Court\u2019s May 5, 2020 decision, and concluded that a CFC\u2019s income \u2018attributable to\u2019 a branch, in this case a manufacturing branch, per se is foreign based company sales income (FBCSI) under the statute if a \u2018substantial tax deferral effect\u2019 is found. They specifically discuss the Maquilladora st...