Bryden,a controlled foreign corporation owned 100% by USCo,earned $900,000 in Subpart F income for the current year.Bryden's current year E & P is $350,000,and its accumulated E & P is $15 million.What is the current year Subpart F deemed dividend to USCo?

Question

Quizplus · Accepted Answer

The Subpart F deemed dividend is limited to the current year earnings and profits (E&P) of the controlled foreign corporation, which is $350,000 in this case.

Bryden,a Controlled Foreign Corporation Owned 100% by USCo,earned $900,000 in Subpart