Which of the following exceptions 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 could cause subpart F income to be excluded from the deemed dividend regime. The de minimis rule exempts certain types of income from being treated as subpart F income, and the high tax rule allows for a foreign tax credit to be claimed for taxes paid to the foreign country where the income was earned, effectively exempting it from U.S. taxation. The full inclusion rule, on the other hand, requires all subpart F income to be included in the deemed dividend regime.

Which of the Following Exceptions Could Cause Subpart F Income