Which of the following statements best describes the primary purpose of the Subpart F income provisions?
A) The Subpart F income provisions provide certainty as to the U.S.income tax treatment of cross-border transactions.
B) The Subpart F income provisions allow deferral of foreign-source income from U.S.taxation.
C) The Subpart F income provisions prevent shifting of income from the United States to low-tax foreign jurisdictions.
D) The Subpart F income provisions prevent shifting of income from the United States to high-tax foreign jurisdictions.
Correct Answer:
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