Page 394 - Large Business IRS Training Guides
P. 394
Foreign Branch Category
Foreign branch category income is excluded from
DEI.
• A foreign branch is a section 989 qualified business
unit
(QBU) that
conducts a trade or business outside the United
States.
• Foreign branch category
income is generally the gross
(recognized for U.S. tax purposes)
income of the taxpayer
that
is recorded on the books of a foreign branch.
excluded from the foreign branch category even if
• Some income is
it i s
on the books of a foreign branch, e.g., income from stock
(unless
an exception applies).
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