All passive income earned by a CFC will be treated as foreign personal holding company income under subpart F for U.S. tax purposes.

Question

Quizplus · Accepted Answer

Not all passive income earned by a Controlled Foreign Corporation (CFC) is treated as Foreign Personal Holding Company Income under Subpart F. There are exceptions and specific provisions that may exclude certain types of income from being classified as Subpart F income, depending on the circumstances and the specific type of income.

All Passive Income Earned by a CFC Will Be Treated