Foreign Sales Corporation Act of 1983

Summary

Foreign Sales Corporation Act of 1983 - Amends the Internal Revenue Code to provide for the tax treatment of foreign sales corporations (FSC) and exports of goods and services. Excludes from gross income the exempt foreign trade income of a foreign sales corporation. Requires the allocation of the deductions of a FSC to its exempt and nonexempt income. Limits the types of income tax credits which a FSC may claim. Treats the foreign trade income (other than exempt foreign trade income), investment income, and carrying charges of FSC as U.S. source income, subject to the income tax. Defines a "FSC" as any corporation which: (1) was created under the laws of any foreign country or possession of the United States; (2) has no more than 25 shareholders at any time during the taxable year; (3) has no preferred stock; (4) maintains an office inside and outside the United States at which permanent tax records are kept; (5) has one director who is not a U.S. resident; (6) is not a member of a controlled group of corporations of which a domestic international sales corporation is a member; and (7) has made an election to be treated as a FSC. Defines a "small foreign sales corporation" as having up to $2,500,000 of export receipts. Sets forth a formula for determining the portion of a FSC's foreign trade income which is exempt foreign trade income. Identifies the gross receipts of any FSC as foreign trading gross receipts which are: (1) from the sale, exchange, or other disposition of export property; (2) from lease or rental of export property for use by the lessee outside the United States; (3) for related services; (4) for engineering or architectural services for construction projects located outside the United States; or (5) for the performance or managerial services. Sets forth rules for the treatment of specified items of income as foreign trading gross receipts. Sets forth transfer pricing rules for the treatment of export property sold to a FSC. Requires the Secretary of the Treasury to prescribe regulations for commissions, rentals, and marginal costing with respect to the sale of export property to a FSC. Sets forth rules for the tax treatment of distributions to shareholders of a FSC. Requires the payment of interest on the deferral of tax on shareholder income of a domestic international sales corporation. Requires the taxable year of a DISC and FSC to conform to the taxable year of the shareholder who holds the highest percentage of voting power.

This text is taken from the official record. PoliticalRepo does not editorialize.

Timeline

No timeline events have been ingested for this record yet.

Votes

No vote records are attached yet.

Versions

No version snapshots stored. Document URLs remain at the source.

Documents

1 official file

• Introduced in Senate

  summary · EN · 4 August 1983

  Open at official source

Sponsors

No sponsors or actors listed by the source.

Related records

No cross-record relationships stored yet.