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R owns 100 percent of F Corporation.In computing earnings and profits, artificial deductions such as the dividends-received deduction are not allowed.Capital losses, including a loss on the sale of property to R, however, are considered true economic losses and reduce earnings and profits even though such losses are not deductible in computing taxable income.
Heavy Machineries
Large and heavy vehicles or equipment used for construction, industrial, or agricultural purposes.
Greenfield Operation
A project where a company builds its operations in a foreign country from the ground up, typically in an area where no previous facilities exist.
Exporting
The process of selling goods or services produced in one country to buyers in another country.
Master Franchise Arrangement
A type of franchise agreement where the master franchisee has the exclusive rights to develop a brand in a particular territory, sub-franchising to others.
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