Tax Type
Corporation Income Tax
Description
Foreign source income
Topic
Computation of Income
Subtractions and Exclusions
Date Issued
10-29-1990
October 29, 1990
Re: §58.1-1821 Application; Corporation Income Tax
-
- §58.1-302 Definitions; Foreign Source Income
Dear**************
This is in response to your letter of October 11, 1989, in which you applied for correction of an assessment of corporation income tax.
Except for the taxable years, the facts are identical to those set forth in my previous letter dated August 30, 1990, P.D. 90-157 (copy enclosed).
I have reviewed the audit and the issues raised in your letter and conclude that there is nothing that would alter the conclusion reached in my previous letter.
The foreign source income subtraction claimed on the 6/30/86, 12/31/86 and 12/31/87 returns is disallowed. It is not necessary to address the other issues you raise in your letter, since they are based on the premise that the income in question qualifies as "technical fees" under the definition of foreign source income.
Determination
Accordingly, t he assessment is correct as made and is now due and payable. You will shortly receive an updated bill with interest accrued to date. The bill should be paid within thirty days to avoid the accrual of additional interest.
Sincerely.
W H. Forst
Tax Commissioner
Rulings of the Tax Commissioner