1. Which of the following would allow a U.S. Corporation that is a shareholder of a Controlled Foreign Corporation (CFC) to defer U.S. tax?

a. The CFC generates taxable income in a foreign jurisdiction with a tax rate higher than the shareholders U.S. tax rate

b. The income of the CFC is not Subpart F Income

c. The CFC distributes after tax earnings to the shareholders

d. All of the above are necessary if the shareholder is to defer U.S. Income taxes on CFC income.