[Code of Federal Regulations] [Title 26, Volume 10] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.927(d)-2T] [Page 122] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.927(d)-2T Temporary regulations; definitions and special rules relating to Foreign Sales Corporation. (a) Definition of related supplier. For purposes of sections 921 through 927 and the regulations under those sections, the term ``related supplier'' means a related party which directly supplies to a FSC any property or services which the FSC disposes of in a transaction producing foreign trading gross receipts, or a related party which uses the FSC as a commission agent in the disposition of any property or services producing foreign trading gross receipts. A FSC may have different related suppliers with respect to different transactions. If, for example, X owns all the stock of Y, a corporation, and of F, a FSC, and X sells a product to Y which is resold to F, only Y is the related supplier of F. If, however, X sells directly to F and Y also sells directly to F, then, as to the transactions involving direct sales to F, each of X and Y is a related supplier of F. (b) Definition of related party. The term ``related party'' means a person which is owned or controlled directly or indirectly by the same interests as the FSC within the meaning of section 482 and Sec. 1.482- 1(a). [T.D. 8126, 52 FR 6465, Mar. 3, 1987] [[Page 123]]