TaxGuided
United States IRC sections

Statute section

IRC section 954

Foreign base company income

Country

United States

Section

954

Updated

2026-05-20

Operative text

Section 954 defines foreign base company income (FBCI), the category of Subpart F income consisting of foreign personal holding company income, foreign base company sales income, and foreign base company services income. Several exclusions (high-tax exception, active financing exception) narrow the scope.

Cross-references

26 U.S.C. 95126 U.S.C. 952

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