[Code of Federal Regulations]
[Title 26, Volume 10]
[Revised as of April 1, 2003]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.927(d)-2T]

[Page 122-123]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1--INCOME TAXES--Table of Contents
 
Sec. 1.927(d)-2T  Temporary regulations; definitions and special rules relating to Foreign Sales Corporation.

    (a) Definition of related supplier. For purposes of sections 921 
through 927 and the regulations under those sections, the term ``related 
supplier'' means a related party which directly supplies to a FSC any 
property or services which

[[Page 123]]

the FSC disposes of in a transaction producing foreign trading gross 
receipts, or a related party which uses the FSC as a commission agent in 
the disposition of any property or services producing foreign trading 
gross receipts. A FSC may have different related suppliers with respect 
to different transactions. If, for example, X owns all the stock of Y, a 
corporation, and of F, a FSC, and X sells a product to Y which is resold 
to F, only Y is the related supplier of F. If, however, X sells directly 
to F and Y also sells directly to F, then, as to the transactions 
involving direct sales to F, each of X and Y is a related supplier of F.
    (b) Definition of related party. The term ``related party'' means a 
person which is owned or controlled directly or indirectly by the same 
interests as the FSC within the meaning of section 482 and Sec. 1.482-
1(a).

[T.D. 8126, 52 FR 6465, Mar. 3, 1987]