PCORPPlains CO2 Reduction Partnership
PCORPPennsylvania Counties Risk Pool (insurance; est. 1987)
References in periodicals archive ?
stock in each CFC on the last day of the taxable year, PCorp must
the tested loss for each of the USSH's CFCs." Since PCorp is
Bl's $50M Subpart F Income is included in PCorp's gross
PCorp's gross income inclusion of Subpart F Income will be
GILTI is an additional Subpart F inclusion in PCorp's gross
In addition, since PCorp receives a FTC for the GILTI inclusion,
PCorp will be deemed to have paid foreign taxes on this revenue and this
equals GILTI ($390M) divided by PCorp's Pro Rata Share of Tested
In this case, PCorp does not have any PTI and further analysis is
PCorp's only potential deductions are the section 162 TorB
potentially deductible under section 164, in this hypothetical PCorp
PCorp is a USSH to all of the CFCs, all three CFCs are STFC.