In Private Letter Ruling 201340010, the IRS extended the manufacturing exception for Subpart F income and applied the exception to products that are grown. The PLR specifically discusses the planted, harvesting and selling of corps by a controlled foreign corporations ("CFC"). Logical extensions of this ruling would be livestock or aqua-culture because the product is "grown."
If anyone ever wanted to own a vineyard in Argentina, this may be news you were waiting for.
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