Assume that John, a Canadian citizen, fails the SPT in 2022 thus making him an RA for U.S. income tax purposes. Further assume that John owns 60% of an FC, a foreign corporation with subpart F income and that FC also has 2 U.S. citizen shareholders, A and B, each owning 20% of FC. If John can successfully claim to be taxed as an NRA under the US/Canada Income Tax Treaty, Article IV dealing with Residence, then the U.S. citizen shareholders, A and B, will not have to pick up any of FC's subpart F income on their respective U.S. income tax returns for 2022.

True

False