The U.S. has a modified territorial system of taxation wherein the earnings of a controlled foreign corporation are subject toimmediate taxation in the U.S.

Question

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Under the U.S. modified territorial system of taxation, the earnings of a controlled foreign corporation are generally not subject to immediate taxation in the U.S. Instead, certain types of passive income may be taxed under Subpart F rules, and the Global Intangible Low-Taxed Income (GILTI) provisions may apply to other income, but there is not an immediate taxation of all foreign earnings.

The US Has a Modified Territorial System of Taxation Wherein the the Earnings