How much, if any, of this income is Subpart F income? Please explain why it is, or is not, Subpart F income?
EuroCo enters into a contract manufacturing agreement with Callahan, an Irish golf club manufacturer. Under the agreement, Callahan agrees to manufacture golf clubs for EuroCo. EuroCo pays for Callahan’s expenses and is responsible for all risk of loss. EuroCo then sells the golf clubs to unrelated buyers throughout Europe.
Is the income from the sale of golf clubs Subpart F income? Please explain why it is, or is not, Subpart F income and what body of law you are relying upon to reach your conclusion?
US Golf (“USG”), a US corporation, manufactures red golf balls and blue golf balls in the US and sells them to EuroCo, a Netherlands corporation which is 100% owned by USG. EuroCo packages the red balls and sells them to independent distributors outside of the Netherlands for a gain of $100. EuroCo packages the blue balls and sells them to independent distributors in the Netherlands for a gain of $200. EuroCo buys white golf balls from an unrelated Japanese manufacturer and sells them to an independent distributor outside of the Netherlands for a gain of $300.
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