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Jokerz, a CFC of a U.S. parent, generated $80,000 Subpart F foreign base company services income in its first year of operations. The next year, Jokerz distributes $50,000 cash to the parent, from those service profits. The parent is taxed on $0 in the first year (tax deferral rules apply) and $50,000 in the second year.
Caterpillar ET
An electronic technician software provided by Caterpillar Inc. to diagnose and program Cat engines and machines.
Gearbox Module
A gearbox module is a self-contained unit consisting of gears and geartrain that changes the speed and torque of a vehicle's power output.
Synchromizers
Mechanisms in a manual transmission that help the gears to synchronize speeds before engaging, for smoother shifting.
Allison TC10
A 10-speed fully automatic transmission designed by Allison for heavy-duty trucks, offering fuel efficiency and seamless shifting for commercial use.
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