Computation of Combined Taxable Income Under the Profit Split Method When the Possession Product Is a Component Product or an End- Product Form

概要

This document contains proposed Income Tax Regulations relating to the determination of combined taxable income under the profit split method. These regulations would amend the current regulations and provide revised rules in order for taxpayers to compute the combined taxable income under profit split when the possession product chosen for purposes of section 936(h)(5) of the Internal Revenue Code is a component product or an end-product form. These regulations are necessary to provide guidance to taxpayers electing the profit split method of computing taxable income under section 936(h)(5).