The US Court of Federal Claims has upheld the position of a taxpayer under the Foreign Sales Corporation (FSC) regime. CBS Corporation & Subsidiaries v. The United States of America, Docket No. 10-153T (11 May 2012). The Court permitted the taxpayer to exclude depreciation attributable to exempt FSC income when computing gain from disposition of an asset sold for export and thus decrease the amount of gain recognized. The case involved a US corporation (CBS) that wholly owned two Bermuda corporations. The Bermuda Corporations were permitted under the former FSC regime (composed of repealed sections 921-927 of the US Internal Revenue...