Common Contracts

Contract

January 18th, 2020

• Filed
  January 18th, 2020

supplier may provide that the FSC will not be the related supplier’s commis- sion agent with respect to sales or leases of export property, or the fur- nishing of services, which do not result in foreign trading gross receipts. In ad- dition, the commission agreement may provide that the FSC will not be the re- lated supplier’s commission agent on transactions which would result in a loss to the related supplier under the transfer pricing rules of section 925(a). In a buy-sell FSC situation, selective commission arrangements are not ap- plicable. Determination of which trans- actions fall within the selective com- mission arrangement may be made up to the due date under section 6072(b), including extensions provided for under section 6081, of the FSC’s income tax return for the taxable year of the FSC during which a transaction occurs.