Which of the Following Exceptions Could Cause Subpart F Income

Which of the following exceptions could cause subpart F income to be excluded from the deemed dividend regime?

A) The full inclusion rule
B) The de minimis rule
C) The high tax rule
D) The de minimis rule and the high tax rule could cause subpart F income to be excluded from the deemed dividend regimE.Under both the de minimis rule and the high tax rule, a U.S.shareholder can elect not to have subpart F income treated as a deemed dividend.