Which of the following exceptions could cause subpart F income to be excluded from the deemed dividend regime?
A)The full inclusion rule only
B)The de minimis rule only
C)The high-tax rule only
D)The de minimis rule and the high-tax rule could cause subpart F income to be excluded from the deemed dividend regime.

Question

Quizplus · Accepted Answer

Both the de minimis rule and the high-tax rule can cause subpart F income to be excluded from the deemed dividend regime. The full inclusion rule, on the other hand, requires that all subpart F income be included in the deemed dividend regime.

Which of the Following Exceptions Could Cause Subpart F Income