Copp,Inc. ,a domestic corporation,owns 40% 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.The CFC 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

Quizplus · Accepted Answer

Copp, Inc. must include in its gross income its pro-rata share of the CFC's Subpart F income. Since Copp owns 40% of the CFC, it must include 40% of $20 million, which is $8 million.

Copp,Inc ,A Domestic Corporation,owns 40% of a CFC That Has