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factory price |
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Commissioner,(1) the United States Tax Court rejected an argument by the Internal Revenue Service that the taxpayer was required to use an independent factory price (IFP) analysis to determine its foreign-source income. Example 1 provides that when (1) the manufacturer regularly sells part of its output to independent distributors in a way that establishes an independent factory price (IFP) for the products sold and (2) the selling or distributing branch of the manufacturer is not located in the same country as the manufacturer's factory, income from sales to customers is allocated between U. Includes such information as model, operator, supporting network, volume, weight, design (type, antenna), launch date and factory price. |
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