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SOI Tax Stats - Controlled Foreign Corporations

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  • Data are taken from Form 5471 - Information Return of U.S. Persons With Respect to Certain Foreign Corporations.
  • For U.S. income tax purposes, a foreign corporation is "controlled" if U.S. shareholders own more than 50% of its outstanding voting stock.
  • Data are also available for the One-Time Dividend Received Deduction reported on Form 8895.

Statistical Tables     SOI Bulletin Articles     Metadata   
 


Statistical Tables

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U.S. Corporations and Their Controlled Foreign Corporations
     Data Presented: Number, Assets, Receipts, Earnings, Taxes, Distributions, Subpart F Income, and Related Party Transactions
     Classified by: Selected NAICS Industrial Sector*
     Tax Years: 2008     2006     2004   
 
     Classified by: Selected Country of Incorporation
     Tax Years: 2008     2006     2004   
 
     Classified by: Selected Country of Incorporation and NAICS Industrial Sector*
     Tax Years: 2008     2006     2004   
 
U.S. Corporations with Total Assets of $500 Million or More and Their 7,500 Largest Controlled Foreign Corporations
     Data Presented: Number, Assets, Receipts, Earnings, Taxes, Distributions, and Subpart F Income
     Classified by: Selected NAICS Industrial Sector*
     Tax Years: 2002   2000   1998   1996   1994   1992   1988
 
     Classified by: Selected Country of Incorporation
     Tax Years: 2002   2000   1998   1996   1994   1992   1988
 
     Classified by: Selected Country of Incorporation and NAICS Industrial Sector*
     Tax Years: 2002   2000   1998   1996   1994   1988


 

U.S. Corporations with Total Assets of $500 Million or More and Their 7,500 Largest Controlled Foreign Corporations
     Data Presented: Number, Assets, Receipts, and Earnings, Standard Industrial Classification (SIC) and North American Industry Classification System (NAICS)
     Classified by: Selected NAICS Industrial Sector
     Tax Year: 1998


*Note:  For Tax Years prior to 1998, industry data are presented by Standard Industry Classification (SIC).  Industry data for Tax Years 1998 to present are presented by North American Industry Classification System (NAICS)


SOI Bulletin Articles

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The Free Online Tax

Free online tax 3. Free online tax   Rent Expense Table of Contents Introduction Topics - This chapter discusses: RentConditional sales contract. Free online tax Leveraged leases. Free online tax Leveraged leases of limited-use property. Free online tax Taxes on Leased Property Cost of Getting a Lease Improvements by Lessee Capitalizing Rent Expenses Introduction This chapter discusses the tax treatment of rent or lease payments you make for property you use in your business but do not own. Free online tax It also discusses how to treat other kinds of payments you make that are related to your use of this property. Free online tax These include payments you make for taxes on the property. Free online tax Topics - This chapter discusses: The definition of rent Taxes on leased property The cost of getting a lease Improvements by the lessee Capitalizing rent expenses Rent Rent is any amount you pay for the use of property you do not own. Free online tax In general, you can deduct rent as an expense only if the rent is for property you use in your trade or business. Free online tax If you have or will receive equity in or title to the property, the rent is not deductible. Free online tax Unreasonable rent. Free online tax   You cannot take a rental deduction for unreasonable rent. Free online tax Ordinarily, the issue of reasonableness arises only if you and the lessor are related. Free online tax Rent paid to a related person is reasonable if it is the same amount you would pay to a stranger for use of the same property. Free online tax Rent is not unreasonable just because it is figured as a percentage of gross sales. Free online tax For examples of related persons, see Related persons in chapter 2, Publication 544. Free online tax Rent on your home. Free online tax   If you rent your home and use part of it as your place of business, you may be able to deduct the rent you pay for that part. Free online tax You must meet the requirements for business use of your home. Free online tax For more information, see Business use of your home in chapter 1. Free online tax Rent paid in advance. Free online tax   Generally, rent paid in your trade or business is deductible in the year paid or accrued. Free online tax If you pay rent in advance, you can deduct only the amount that applies to your use of the rented property during the tax year. Free online tax You can deduct the rest of your payment only over the period to which it applies. Free online tax Example 1. Free online tax You are a calendar year taxpayer and you leased a building for 5 years beginning July 1. Free online tax Your rent is $12,000 per year. Free online tax You paid the first year's rent ($12,000) on June 30. Free online tax You can deduct only $6,000 (6/12 × $12,000) for the rent that applies to the first year. Free online tax Example 2. Free online tax You are a calendar year taxpayer. Free online tax Last January you leased property for 3 years for $6,000 a year. Free online tax You paid the full $18,000 (3 × $6,000) during the first year of the lease. Free online tax Each year you can deduct only $6,000, the part of the lease that applies to that year. Free online tax Canceling a lease. Free online tax   You generally can deduct as rent an amount you pay to cancel a business lease. Free online tax Lease or purchase. Free online tax   There may be instances in which you must determine whether your payments are for rent or for the purchase of the property. Free online tax You must first determine whether your agreement is a lease or a conditional sales contract. Free online tax Payments made under a conditional sales contract are not deductible as rent expense. Free online tax Conditional sales contract. Free online tax   Whether an agreement is a conditional sales contract depends on the intent of the parties. Free online tax Determine intent based on the provisions of the agreement and the facts and circumstances that exist when you make the agreement. Free online tax No single test, or special combination of tests, always applies. Free online tax However, in general, an agreement may be considered a conditional sales contract rather than a lease if any of the following is true. Free online tax The agreement applies part of each payment toward an equity interest you will receive. Free online tax You get title to the property after you make a stated amount of required payments. Free online tax The amount you must pay to use the property for a short time is a large part of the amount you would pay to get title to the property. Free online tax You pay much more than the current fair rental value of the property. Free online tax You have an option to buy the property at a nominal price compared to the value of the property when you may exercise the option. Free online tax Determine this value when you make the agreement. Free online tax You have an option to buy the property at a nominal price compared to the total amount you have to pay under the agreement. Free online tax The agreement designates part of the payments as interest, or that part is easy to recognize as interest. Free online tax Leveraged leases. Free online tax   Leveraged lease transactions may not be considered leases. Free online tax Leveraged leases generally involve three parties: a lessor, a lessee, and a lender to the lessor. Free online tax Usually the lease term covers a large part of the useful life of the leased property, and the lessee's payments to the lessor are enough to cover the lessor's payments to the lender. Free online tax   If you plan to take part in what appears to be a leveraged lease, you may want to get an advance ruling. Free online tax Revenue Procedure 2001-28 on page 1156 of Internal Revenue Bulletin 2001-19 contains the guidelines the IRS will use to determine if a leveraged lease is a lease for federal income tax purposes. Free online tax Revenue Procedure 2001-29 on page 1160 of the same Internal Revenue Bulletin provides the information required to be furnished in a request for an advance ruling on a leveraged lease transaction. Free online tax Internal Revenue Bulletin 2001-19 is available at www. Free online tax irs. Free online tax gov/pub/irs-irbs/irb01-19. Free online tax pdf. Free online tax   In general, Revenue Procedure 2001-28 provides that, for advance ruling purposes only, the IRS will consider the lessor in a leveraged lease transaction to be the owner of the property and the transaction to be a valid lease if all the factors in the revenue procedure are met, including the following. Free online tax The lessor must maintain a minimum unconditional “at risk” equity investment in the property (at least 20% of the cost of the property) during the entire lease term. Free online tax The lessee may not have a contractual right to buy the property from the lessor at less than fair market value when the right is exercised. Free online tax The lessee may not invest in the property, except as provided by Revenue Procedure 2001-28. Free online tax The lessee may not lend any money to the lessor to buy the property or guarantee the loan used by the lessor to buy the property. Free online tax The lessor must show that it expects to receive a profit apart from the tax deductions, allowances, credits, and other tax attributes. Free online tax   The IRS may charge you a user fee for issuing a tax ruling. Free online tax For more information, see Revenue Procedure 2014-1 available at  www. Free online tax irs. Free online tax gov/irb/2014-1_IRB/ar05. Free online tax html. Free online tax Leveraged leases of limited-use property. Free online tax   The IRS will not issue advance rulings on leveraged leases of so-called limited-use property. Free online tax Limited-use property is property not expected to be either useful to or usable by a lessor at the end of the lease term except for continued leasing or transfer to a lessee. Free online tax See Revenue Procedure 2001-28 for examples of limited-use property and property that is not limited-use property. Free online tax Leases over $250,000. Free online tax   Special rules are provided for certain leases of tangible property. Free online tax The rules apply if the lease calls for total payments of more than $250,000 and any of the following apply. Free online tax Rents increase during the lease. Free online tax Rents decrease during the lease. Free online tax Rents are deferred (rent is payable after the end of the calendar year following the calendar year in which the use occurs and the rent is allocated). Free online tax Rents are prepaid (rent is payable before the end of the calendar year preceding the calendar year in which the use occurs and the rent is allocated). Free online tax These rules do not apply if your lease specifies equal amounts of rent for each month in the lease term and all rent payments are due in the calendar year to which the rent relates (or in the preceding or following calendar year). Free online tax   Generally, if the special rules apply, you must use an accrual method of accounting (and time value of money principles) for your rental expenses, regardless of your overall method of accounting. Free online tax In addition, in certain cases in which the IRS has determined that a lease was designed to achieve tax avoidance, you must take rent and stated or imputed interest into account under a constant rental accrual method in which the rent is treated as accruing ratably over the entire lease term. Free online tax For details, see section 467 of the Internal Revenue Code. Free online tax Taxes on Leased Property If you lease business property, you can deduct as additional rent any taxes you have to pay to or for the lessor. Free online tax When you can deduct these taxes as additional rent depends on your accounting method. Free online tax Cash method. Free online tax   If you use the cash method of accounting, you can deduct the taxes as additional rent only for the tax year in which you pay them. Free online tax Accrual method. Free online tax   If you use an accrual method of accounting, you can deduct taxes as additional rent for the tax year in which you can determine all the following. Free online tax That you have a liability for taxes on the leased property. Free online tax How much the liability is. Free online tax That economic performance occurred. Free online tax   The liability and amount of taxes are determined by state or local law and the lease agreement. Free online tax Economic performance occurs as you use the property. Free online tax Example 1. Free online tax Oak Corporation is a calendar year taxpayer that uses an accrual method of accounting. Free online tax Oak leases land for use in its business. Free online tax Under state law, owners of real property become liable (incur a lien on the property) for real estate taxes for the year on January 1 of that year. Free online tax However, they do not have to pay these taxes until July 1 of the next year (18 months later) when tax bills are issued. Free online tax Under the terms of the lease, Oak becomes liable for the real estate taxes in the later year when the tax bills are issued. Free online tax If the lease ends before the tax bill for a year is issued, Oak is not liable for the taxes for that year. Free online tax Oak cannot deduct the real estate taxes as rent until the tax bill is issued. Free online tax This is when Oak's liability under the lease becomes fixed. Free online tax Example 2. Free online tax The facts are the same as in Example 1 except that, according to the terms of the lease, Oak becomes liable for the real estate taxes when the owner of the property becomes liable for them. Free online tax As a result, Oak will deduct the real estate taxes as rent on its tax return for the earlier year. Free online tax This is the year in which Oak's liability under the lease becomes fixed. Free online tax Cost of Getting a Lease You may either enter into a new lease with the lessor of the property or get an existing lease from another lessee. Free online tax Very often when you get an existing lease from another lessee, you must pay the previous lessee money to get the lease, besides having to pay the rent on the lease. Free online tax If you get an existing lease on property or equipment for your business, you generally must amortize any amount you pay to get that lease over the remaining term of the lease. Free online tax For example, if you pay $10,000 to get a lease and there are 10 years remaining on the lease with no option to renew, you can deduct $1,000 each year. Free online tax The cost of getting an existing lease of tangible property is not subject to the amortization rules for section 197 intangibles discussed in chapter 8. Free online tax Option to renew. Free online tax   The term of the lease for amortization includes all renewal options plus any other period for which you and the lessor reasonably expect the lease to be renewed. Free online tax However, this applies only if less than 75% of the cost of getting the lease is for the term remaining on the purchase date (not including any period for which you may choose to renew, extend, or continue the lease). Free online tax Allocate the lease cost to the original term and any option term based on the facts and circumstances. Free online tax In some cases, it may be appropriate to make the allocation using a present value computation. Free online tax For more information, see Regulations section 1. Free online tax 178-1(b)(5). Free online tax Example 1. Free online tax You paid $10,000 to get a lease with 20 years remaining on it and two options to renew for 5 years each. Free online tax Of this cost, you paid $7,000 for the original lease and $3,000 for the renewal options. Free online tax Because $7,000 is less than 75% of the total $10,000 cost of the lease (or $7,500), you must amortize the $10,000 over 30 years. Free online tax That is the remaining life of your present lease plus the periods for renewal. Free online tax Example 2. Free online tax The facts are the same as in Example 1, except that you paid $8,000 for the original lease and $2,000 for the renewal options. Free online tax You can amortize the entire $10,000 over the 20-year remaining life of the original lease. Free online tax The $8,000 cost of getting the original lease was not less than 75% of the total cost of the lease (or $7,500). Free online tax Cost of a modification agreement. Free online tax   You may have to pay an additional “rent” amount over part of the lease period to change certain provisions in your lease. Free online tax You must capitalize these payments and amortize them over the remaining period of the lease. Free online tax You cannot deduct the payments as additional rent, even if they are described as rent in the agreement. Free online tax Example. Free online tax You are a calendar year taxpayer and sign a 20-year lease to rent part of a building starting on January 1. Free online tax However, before you occupy it, you decide that you really need less space. Free online tax The lessor agrees to reduce your rent from $7,000 to $6,000 per year and to release the excess space from the original lease. Free online tax In exchange, you agree to pay an additional rent amount of $3,000, payable in 60 monthly installments of $50 each. Free online tax   You must capitalize the $3,000 and amortize it over the 20-year term of the lease. Free online tax Your amortization deduction each year will be $150 ($3,000 ÷ 20). Free online tax You cannot deduct the $600 (12 × $50) that you will pay during each of the first 5 years as rent. Free online tax Commissions, bonuses, and fees. Free online tax   Commissions, bonuses, fees, and other amounts you pay to get a lease on property you use in your business are capital costs. Free online tax You must amortize these costs over the term of the lease. Free online tax Loss on merchandise and fixtures. Free online tax   If you sell at a loss merchandise and fixtures that you bought solely to get a lease, the loss is a cost of getting the lease. Free online tax You must capitalize the loss and amortize it over the remaining term of the lease. Free online tax Improvements by Lessee If you add buildings or make other permanent improvements to leased property, depreciate the cost of the improvements using the modified accelerated cost recovery system (MACRS). Free online tax Depreciate the property over its appropriate recovery period. Free online tax You cannot amortize the cost over the remaining term of the lease. Free online tax If you do not keep the improvements when you end the lease, figure your gain or loss based on your adjusted basis in the improvements at that time. Free online tax For more information, see the discussion of MACRS in Publication 946, How To Depreciate Property. Free online tax Assignment of a lease. Free online tax   If a long-term lessee who makes permanent improvements to land later assigns all lease rights to you for money and you pay the rent required by the lease, the amount you pay for the assignment is a capital investment. Free online tax If the rental value of the leased land increased since the lease began, part of your capital investment is for that increase in the rental value. Free online tax The rest is for your investment in the permanent improvements. Free online tax   The part that is for the increased rental value of the land is a cost of getting a lease, and you amortize it over the remaining term of the lease. Free online tax You can depreciate the part that is for your investment in the improvements over the recovery period of the property as discussed earlier, without regard to the lease term. Free online tax Capitalizing Rent Expenses Under the uniform capitalization rules, you must capitalize the direct costs and part of the indirect costs for certain production or resale activities. Free online tax Include these costs in the basis of property you produce or acquire for resale, rather than claiming them as a current deduction. Free online tax You recover the costs through depreciation, amortization, or cost of goods sold when you use, sell, or otherwise dispose of the property. Free online tax Indirect costs include amounts incurred for renting or leasing equipment, facilities, or land. Free online tax Uniform capitalization rules. Free online tax   You may be subject to the uniform capitalization rules if you do any of the following, unless the property is produced for your use other than in a business or an activity carried on for profit. Free online tax Produce real property or tangible personal property. Free online tax For this purpose, tangible personal property includes a film, sound recording, video tape, book, or similar property. Free online tax Acquire property for resale. Free online tax However, these rules do not apply to the following property. Free online tax Personal property you acquire for resale if your average annual gross receipts are $10 million or less for the 3 prior tax years. Free online tax Property you produce if you meet either of the following conditions. Free online tax Your indirect costs of producing the property are $200,000 or less. Free online tax You use the cash method of accounting and do not account for inventories. Free online tax Example 1. Free online tax You rent construction equipment to build a storage facility. Free online tax If you are subject to the uniform capitalization rules, you must capitalize as part of the cost of the building the rent you paid for the equipment. Free online tax You recover your cost by claiming a deduction for depreciation on the building. Free online tax Example 2. Free online tax You rent space in a facility to conduct your business of manufacturing tools. Free online tax If you are subject to the uniform capitalization rules, you must include the rent you paid to occupy the facility in the cost of the tools you produce. Free online tax More information. Free online tax   For more information on these rules, see Uniform Capitalization Rules in Publication 538 and the regulations under Internal Revenue Code section 263A. Free online tax Prev  Up  Next   Home   More Online Publications