Items included
(a) Items included. Except as provided in paragraph (d) of this section, foreign base company services income means income of a controlled foreign corporation, whether in the form of compensation, commissions, fees, or otherwise, derived in connection with the performance of technical, managerial, engineering, architectural, scientific, skilled, industrial, commercial, or like services which (1) Are performed for, or on behalf of a related person, as defined in paragraph (e)(1) of 1.954-1, and (2) Are performed outside the country under the laws of which the controlled foreign corporation is created or organized.