Subpart F income earned by a CFC will always be treated as a deemed dividend to the CFC's U.S. shareholders in the year the subpart F income is earned.
The subpart F income could be excluded from being a deemed dividend under a de minimis rule if the gross amount of the income is less than the lesser of $1 million or five percent of gross income.

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The Answer of Subpart F income earned by a CFC will always be treated as a deemed dividend to the CFC's U.S. shareholders in the year the subpart F income is earned.
The subpart F income could be excluded from being a deemed dividend under a de minimis rule if the gross amount of the income is less than the lesser of $1 million or five percent of gross income.

Subpart F Income Earned by a CFC Will Always Be