Per IRS guidance, the cash position of any specified foreign corporation is the sum of:
- Cash held by such corporation,
- The net accounts receivable of such corporation (accounts receivable net of accounts payable, and
- The fair market value of the following assets held by such corporation:
- Personal property which is of a type that is actively traded and for which there is an established financial market;
- Commercial paper, certificates of deposit, the securities of the Federal government and of any State or foreign government;
- Any foreign currency;
- Any note receivable with a term of less than one year.