ForCo,a controlled foreign corporation,earns $500,000 in net interest and dividend income from investments in the bonds and stock of unrelated companies.All the unrelated companies are located in ForCo's country of incorporation.ForCo's Subpart F income for the year is:

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The Subpart F income is $500,000 as all this income represents foreign personal holding company income.The same country exception does not apply because the payors are unrelated.Whether ForCo is engaged in a trade or business in its home country is not relevant.

ForCo,a Controlled Foreign Corporation,earns $500,000 in Net Interest and Dividend