The income of a foreign subsidiary is not taxable until dividends are distributed to the U.S. parent unless:

Question

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Subpart F income refers to certain types of passive income earned by controlled foreign corporations (CFCs) that are subject to current U.S. taxation, regardless of whether they are distributed as dividends to the U.S. parent. This means that even if the foreign subsidiary has not distributed any dividends, the U.S. parent may still have to pay tax on the Subpart F income.

The Income of a Foreign Subsidiary Is Not Taxable Until