### Question
Can you define what foreign base company services income means?


### Answer
**Foreign base company services income** is defined as the following in *26 U.S.C. § 954*:

> income (whether in the form of compensation, commissions, fees, or otherwise) derived in connection with the performance of technical, managerial, engineering, architectural, scientific, skilled, industrial, commercial, or like services which—



(A) are performed for or on behalf of any related person (within the meaning of subsection (d)(3)), and



(B) are performed outside the country under the laws of which the controlled foreign corporation is created or organized

#### Citation:
  - *26 U.S.C. § 954*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART III-INCOME FROM SOURCES WITHOUT THE UNITED STATES > Subpart F-Controlled Foreign Corporations**

