Page 19 - Large Business IRS Training Guides

Taxpayer’s
Aggregate Group (cont’d) 1

–
2) Exclude foreign corporations

• Except with regard to income that is, or is

treated as, effectively connected with the

in the United
conduct of a trade or business

States (“ECI”); or

• if the foreign corporation determines
its net
income under a treaty, except with regard to

net
income taken into account in determining its
taxable income

17