FBPRFeature-Based Pattern Recognition (image processsing technique)
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When calculating the foreign base period ratio (FBPR) (Prop.
(14) The drafters of the regulation recognized this problem and crafted a rule that allows taxpayers with no CFCs at the effective date of the regulations to have as a minimum base an FBPR and U.S.
shareholder will not have ERGI for the year if (i) the related group indebtedness does not exceed the immediately preceding year's allowable related group indebtedness; (ii) the related group debt-asset ratio for the year does not exceed its FBPR; or (iii) the related group debt-to-asset ratio does not exceed 10 percent.