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.