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Internal Revenue Bulletin:  2009-18 

May 4, 2009 


Table of Contents

Announcement 2009-36 Announcement 2009-36

This document cancels a public hearing on proposed regulations (REG-150066-08, 2009-5 I.R.B. 423) relating to the foreign base company sales income, in cases in which personal property sold by a controlled foreign corporation (CFC) is manufactured, produced, or constructed pursuant to a contract manufacturing arrangement or by one or more branches of the CFC. The temporary regulations modify the foreign base company sales income regulations to address current business structures and practices, particulary the growing importance of contract manufacturing and other manufacturing arrangements. The temporary regulations, in general, will affect CFCs and their United States shareholders.

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