In which of the following cases are the U.S. shareholders in a controlled foreign corporation (CFC) avoiding U.S. tax on the CFC's income?

Question

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In option B, the U.S. shareholders are avoiding U.S. tax on the CFC's income because the income is neither subpart F income nor global intangible low-taxed income (GILTI), and no dividends are paid out. This means the income remains untaxed by the U.S. until it is repatriated, if ever. Options A, C, and D involve types of income (subpart F income or GILTI) that are subject to current U.S. taxation regardless of whether dividends are distributed, thus not allowing for tax avoidance in the same manner.

In Which of the Following Cases Are the U