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Adele, a U.S. shareholder under the CFC provisions, owns 40% of a foreign Corp. named Sullivan- Global. If the CFCs Subpart F income for the

Adele, a U.S. shareholder under the CFC provisions, owns 40% of a foreign Corp. named Sullivan- Global. If the CFC’s Subpart F income for the taxable year is $200,000, Adele is taxed on receipt of a constructive dividend of…

a. $200,000

b. $80,000

c. 0

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