24 August 2016 External T.I. 2015-0592921E5 - Computation of Earnings of a Foreign Affiliate -- summary under Subparagraph (a)(iii)

A Singapore company was not required under Singapore income tax law to compute its income from its active business activities carried on through the branches in each of a designated treaty country and one which was not until a subsequent taxation year when their profits were remitted to Singapore. Accordingly, the branch earnings were to be determined under the income tax law of the designated treaty county (under (a)(ii) of the “earnings” definition in Reg. 5907(1)), or under modified Canadian tax rules (under (a)(iii) of that definition), as the case may be.