Rhode Island Code of Regulations › Title 280 - Department of Revenue › Chapter 20 - Division of Taxation › Subchapter 25 - Business Corporation Tax › Part 15 - Treatment of Repatriated Income 2017 (280-RICR-20-25-15) › Section 280-RICR-20-25-15.6 - Definitions

Current through June 14, 2024
A. "965 Income" means the accumulated
				 post-1986 deferred foreign income of deferred foreign income corporations
				 earned before the end of calendar year 2017 that is included as gross income by
				 a U.S. shareholder under
				  26 U.S.C. §
											951(a)(1) pursuant to
				  26 U.S.C. §
											965(a).
B. "Apportionment" means the same as its
				 definition set forth in the Division's Combined Reporting regulation (Part 10
				 of this Subchapter).
C. "Combined
				 reporting" means the same as its definition set forth in the Division's
				 Combined Reporting regulation (Part 10 of this Subchapter).
D. "Common ownership" means the same as its
				 definition set forth in the Division's Combined Reporting regulation (Part 10
				 of this Subchapter).
E.
				 "Corporation" means the same as its definition set forth in the Division's
				 Combined Reporting regulation (Part 10 of this Subchapter) and Apportionment of
				 Net Income regulation (Part 9 of this Subchapter).
F. "Deferred foreign income corporation"
				 means the same as its definition set forth in
				  26 U.S.C. §
											965(d).
G. "Dividend received deduction" or "DRD"
				 means a Rhode Island tax deduction not provided by the Internal Revenue Code
				 that a C corporation may claim that is equal to a percentage of the dividends
				 that it receives from, or the Subpart F Income attributable to, foreign
				 corporations whose stock it owns, as defined by the Internal Revenue Code prior
				 to the enactment of the TCJA and as prescribed by the RI-1120C.
H. "Division of Taxation" means the Rhode
				 Island Department of Revenue, Division of Taxation. The Division may also be
				 referred to in this regulation as the "Division of Taxation", "Tax Division",
				 or "Division".
I. "Foreign
				 corporation" means the same as its definition set forth in the Division's
				 Combined Reporting regulation (Part 10 of this Subchapter).
J. "Internal Revenue Code" or "IRC" means the
				 most current edition of Title 26 of the United States Code.
K. "Member" means the same as its definition
				 set forth in the Division's Combined Reporting regulation (Part 10 of this
				 Subchapter).
L. "Net income" means
				 Rhode Island net income as defined in R.I. Gen. Laws §
										44-11-11,
				 as amended. This includes Net 965 Income since Rhode Island net income is
				 broadly defined as a taxpayer's taxable income under the laws of the United
				 States, and no exclusions under R.I. Gen. Laws §
										44-11-11,
				 as amended, apply to Net 965 Income.
M. "Net 965 income" means 965 Income less any
				 federal deductions provided by
				  26 U.S.C. §
											965.
N. "Nonunitary foreign corporation
				 subsidiary" means any foreign corporation subsidiary that both:
1. is not a combined group member with the
				 corporation that recognizes such income; and
2. would not be a combined group member with
				 the corporation that recognizes the income if the water's edge rules did not
				 apply.
3. The preceding principles
				 apply whether the corporation that recognizes the Net 965 Income files as part
				 of a combined group or files a separate return.