Copp, Inc., a domestic corporation, owns 30% of a CFC that has $50 million of earnings and profits for the current year.Included in that amount is $20 million of Subpart F income.Copp has been a CFC for the entire year and makes no distributions in the current year.Copp must include in gross income (before any § 78 gross-up):

Question

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Copp, Inc. must include in its gross income its pro-rata share of the CFC's Subpart F income. Since Copp owns 30% of the CFC, it must include 30% of $20 million, which is $6 million, in its gross income.

Copp, Inc, a Domestic Corporation, Owns 30% of a CFC That