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Get Revenue Ruling 1997 - 48 - This Ruling Revokes Rev. Rul. 75-7, 1975 ...

Ds that the activities of a contract manufacturer cannot be attributed to a controlled foreign corporation for purposes of either section 954(d)(1) or section 954(d)(2) of the Code to determine whether the income of a controlled foreign corporation is foreign base company sales income. The ruling, however, provides 7805(b) relief for taxable years of a controlled foreign corporation beginning before December 8, 1997. Rev. Rul. 97 48 In Rev. Rul. 75 7, 1975 1 C.B. 244, a controlled foreign.

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