Page 732 - Large Business IRS Training Guides

Related Parties & AFCP

of determining the AFCP of a section 958(a) U.S. shareholder,
• For purposes
receivable and payable, short-term obligations, and derivative
accounts
financial
instruments between related SFCs are in certain circumstances
dates of the SFCs to the
disregarded on the corresponding cash measurement
extent
of the smallest ownership percentage of stock owned by the section
958(a)
U.S. shareholder on the corresponding measurement dates.

SFC if the SFCs are related persons
• An SFC is treated as related to another
within the meaning of
section 954(d)(3), substituting SFC for CFC.

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