affiliate with


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For those taxpayers who sell part of a foreign affiliate with the intention of retaining some interest in the purchaser or the business, the rules may be so restrictive that the taxpayer may never be able to access the surplus associated with the sale.
This has invited involvement of the affiliate with not only a number of state agencies and programs, but with private service providers and residential facilities as well.
For example, if the group is composed of one affiliate with a billion dollars in active business assets that earns $8 million in a particular year, and two other affiliates, one which earns $1 million of FAPI and one which has a $1 million FAPI loss, the test will not be met.

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