Here and There by ProQuest


On October 22, 2004, Congress passed the American Jobs Creation Act of 2004 (AJCA), which included significant tax reforms for the international transportation equipment leasing industry. As a way to increase the competitiveness of U.S. vessel and aircraft operators and lessors, AJCA section 415 repealed the foreign base company shipping income provisions that generally required the current inclusion of income derived by a controlled foreign corporation (CFC) from the leasing of vessels and aircraft.In part, the provisions were a compromise intended to replace the benefits of the Extraterritorial Income and Foreign Sales Corporation exclusions for sales and leases of U.S. manufactured property repealed by the AJCA. If a U.S. lessor engages in leasing of transportation property through a CFC and complies with the provisions of the AJCA, the income may be eligible for deferral from U.S. taxation until it is deemed to be repatriated

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