Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 75-69

1975-1 C.B. 253

Sec. 993

IRS Headnote

P is a domestic corporation engaged in the construction business. S is a wholly-owned subsidiary of P that qualifies as a Domestic International Sales Corporation (DISC) under section 992 of the Internal Revenue Code of 1954.

Full Text

Rev. Rul. 75-69

P proposes to have S act as its commission agent with respect to certain engineering services to be performed by P in foreign country M relating to construction projects. Some of the employees of P who will perform the engineering services live outside of the United States and are not United States citizens.

Section 993(a)(1)(G) of the Code provides, in part, that the qualified export receipts of a corporation include gross receipts for engineering services for construction projects located (or proposed for location) outside the United States.

Held, the fact that the engineering services will be performed by employees of P, who live outside the United States and who are not United States citizens, will not by itself preclude the amount of gross receipts received by P from the engineering services from qualifying as qualified export receipts of S within the meaning of section 993(a) of the Code.