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Charles White, a U.S. citizen, owns 1% of FORCO, a foreign corporation which owns 100% of two active operating companies, FOROP 1 and FOROP 2.
Charles White, a U.S. citizen, owns 1% of FORCO, a foreign corporation which owns 100% of two active operating companies, FOROP 1 and FOROP 2. In 2022, all of FORCO's income stems from dividends received from FOROP 1 and FOROP 2. As such, FORCO will meet the 75% or more passive income test and will constitute a PFIC as to Charles. True or False
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