Section 280-RICR-20-25-15.6 - DefinitionsA. "965 Income" means the accumulated post-1986 deferred foreign income of deferred foreign income corporations earned before the end of calendar year 2017 that is included as gross income by a U.S. shareholder under 26 U.S.C. § 951(a)(1) pursuant to 26 U.S.C. § 965(a).B. "Apportionment" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).C. "Combined reporting" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).D. "Common ownership" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).E. "Corporation" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter) and Apportionment of Net Income regulation (Part 9 of this Subchapter).F. "Deferred foreign income corporation" means the same as its definition set forth in 26 U.S.C. § 965(d).G. "Dividend received deduction" or "DRD" means a Rhode Island tax deduction not provided by the Internal Revenue Code that a C corporation may claim that is equal to a percentage of the dividends that it receives from, or the Subpart F Income attributable to, foreign corporations whose stock it owns, as defined by the Internal Revenue Code prior to the enactment of the TCJA and as prescribed by the RI-1120C.H. "Division of Taxation" means the Rhode Island Department of Revenue, Division of Taxation. The Division may also be referred to in this regulation as the "Division of Taxation", "Tax Division", or "Division".I. "Foreign corporation" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).J. "Internal Revenue Code" or "IRC" means the most current edition of Title 26 of the United States Code.K. "Member" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).L. "Net income" means Rhode Island net income as defined in R.I. Gen. Laws § 44-11-11, as amended. This includes Net 965 Income since Rhode Island net income is broadly defined as a taxpayer's taxable income under the laws of the United States, and no exclusions under R.I. Gen. Laws § 44-11-11, as amended, apply to Net 965 Income.M. "Net 965 income" means 965 Income less any federal deductions provided by 26 U.S.C. § 965.N. "Nonunitary foreign corporation subsidiary" means any foreign corporation subsidiary that both: 1. is not a combined group member with the corporation that recognizes such income; and2. would not be a combined group member with the corporation that recognizes the income if the water's edge rules did not apply.3. The preceding principles apply whether the corporation that recognizes the Net 965 Income files as part of a combined group or files a separate return.O. "Partnership" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).P. "Pass-through entity" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).Q. "Rhode Island combined group" means the same as the definition of "combined group" set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter). R. "Single sales factor" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).S. "Subpart F income" means the same as its definition set forth in 26 U.S.C. § 952.T. "Tax administrator" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).U. "Three-factor apportionment" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).V. "Transition tax" means any one-time increase in Rhode Island income tax arising from the recognition of 965 Income.W. "Unitary business" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).X. "Unitary foreign corporation subsidiary" means any foreign corporation subsidiary that both: 1. is not a combined group member with the corporation that recognizes such income; and2. would be a combined group member with the corporation that recognizes the income if the water's edge rules did not apply. The preceding principles apply whether the corporation that recognizes the Net 965 Income files as part of a combined group or files a separate return.3. The preceding principles apply whether the corporation that recognizes the Net 965 Income files as part of a combined group or files a separate return.Y. "Water's edge rules" means the same as its definition set forth in the Division's Combined Reporting regulation (Part 10 of this Subchapter).Z. Any term used in this Regulation and not defined herein shall have the same meaning as when used in a comparable context in other Rhode Island regulations relating to corporate income tax, unless a different meaning is clearly required.280 R.I. Code R. 280-RICR-20-25-15.6