Section 954

Subject to section 912 and except as otherwise provided in this article the client whether or not a party has a privilege to refuse to disclose and to prevent another from disclosing a confidential communication between client and lawyer if the privilege is claimed by.

Section 954. For purposes of section 954 c 3 a of the internal revenue code of 1986 any dividends received by a qualified controlled foreign corporation within the meaning of section 951 of such code during any of its 1st 5 taxable years beginning after december 31 1986 with respect to its 32 7 percent interest in a brazilian corporation shall be treated as if such brazilian corporation were a related person to the qualified controlled foreign corporation to the extent the brazilian corporation. Or the sale by the partnership of personal property to or the purchase of personal property by the. Any gross income excluded from the foreign base company income as defined in section 954 and the insurance income as defined in section 953 of such corporation by reason of section 954 b 4 iv.

Prior to amendment text of par. For purposes of section 954 c 3 a of the internal revenue code of 1986 any dividends received by a qualified controlled foreign corporation within the meaning of section 951 of such code during any of its 1st 5 taxable years beginning after december 31 1986 with respect to its 32 7 percent interest in a brazilian corporation shall be treated as if such brazilian corporation were a related person to the qualified controlled foreign corporation to the extent the brazilian corporation. 10 read as follows.

Section 954 c 6 has displayed remarkable longevity for a temporary provision. A the holder of the privilege. The treasury department and the irs have determined that the policy goal of section 954 b 4 is to identify income of a cfc subject to a high effective rate of foreign tax and is better served by determining the effective foreign tax rate with respect to items of income attributable to a tested unit by reference to an amount of income that approximates taxable income as computed for foreign tax purposes rather than federal income tax purposes.

For purposes of determining whether a controlled foreign corporation s distributive share of any item of gross income of a partnership is foreign base company sales income under section 954 d 1 when the item of income is derived from the sale by the partnership of personal property purchased by the partnership from or sold by the partnership on behalf of the controlled foreign corporation. This subsection and section 954 i shall apply only to taxable years of a foreign corporation beginning after december 31 1998 and before january 1 2015 and to taxable years of united states shareholders with or. The amendments made by this section amending this section and section 954 of this title shall apply to taxable years of foreign corporations beginning after december 31 2004 and to taxable years of united states shareholders with or within which such taxable years of foreign corporations end.