Before Subpart F Applies, a Foreign Corporation Must Be a CFC

Before subpart F applies, a foreign corporation must be a CFC for how many consecutive days?

A) 1
B) 30
C) 183
D) 365
ESSAY. Write your answer in the space provided or on a separate sheet of paper.
80) Nicole is a citizen and resident of Australia. She has a full-time job in Australia and has lived there with her family for the past 10 years. In 2018, Nicole came to the United States on business and stayed for 180 days. She came to the United States again on business in 2019 and stayed for 150 days. In 2020 she came back to the United States on business and stayed for 100 days. Does Nicole meet the U.S. statutory definition of a resident alien in 2020 under the substantial presence test?