United States shareholders may elect to determine foreign base company shipping income and qualified investments in foreign base company shipping operations of controlled foreign corporations on a consolidated basis (rather than on a corporation by corporation basis).
Under Treas. Reg. §1.955A 3(d)each United States shareholder shall attach to his return a statement setting forth the adjusted basis of the property before the reduction and the amount and nature of the reduction. The election will be effective for all years thereafter until revoked with the approval of the Commissioner of Internal Revenue. The request for consent for revocation of the election under Treas. Reg. §1.955A 3(D)(2)shall be made by mailing a letter for such purpose to the Commissioner of Internal Revenue Service containing a statement of the facts which justify such consent.
US Code:
26 USC 954
Name of Law: Foreign Base Company Income
US Code:
26 USC 955
Name of Law: Withdrawal of Previously Excluded Subpart F Income from Qualified Investment
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.