1. Glass, Inc., a corporation organized in UK, has 100 shares of common stock. The shares are voting shares. Ownership of Glass is as follows.

• Ben, an Israeli individual, owns 20 shares
• Sarah, a US person, owns 20 shares
• Abigail, a US person, owns 30 shares
• Helen, a US person, owns 30 shares

Is Glass a CFC? Who are the US shareholders?

2. Paper, Inc., a corporation organized in Germany, has the following owners, all owner voting shares:

• 15% owned by Ben, a US individual
• 10% owned by Sarah, a US individual
• 75% Fork, LLP, a foreign partnership
  • Fork has the following partners
    • 15% owned by Abigail, a US individual
    • 15% owned by Helen, a US individual
    • 15% owned by Lauren, a US individual
    • 10% owned by Abe, a US individual
    • 10% owned by Adele, a US individual
    • 15% owned by Mark, a foreign individual
    • 15% owned by Nate, a foreign individual
    • 5% owned by Lynn, a foreign individual

Is Paper Inc. a CFC? Who are the US shareholders?

3. Wall Inc., a US corporation, owns 100% of the following subsidiaries.

• Floor Inc. a foreign corporation organized in Germany
• Ceiling Inc., a foreign corporation organized France

Floor buys product from Wall and sells it to Ceiling. It earned pre-tax income of $5,000 on such sales and paid $1,000 of tax. Floor has no depreciable tangible assets.

Ceiling sells the product it buys from Floor to customers located in France. It earns $6,000 pre-tax income on such sales and pays $1,250 on such income. Ceiling has $1,000 of basis in its tangible depreciable assets.

What amount of Subpart F income does Wall need to include? What is the total income inclusion Wall has to pick up assuming Wall takes a foreign tax credit? What is Walls US tax obligation after foreign tax credits?