Emill Corporation, a French corporation, is owned by the following unrelated persons: 50 percent by a U.S. corporation, 5 percent by a U.S. individual, and 45 percent by a Swiss corporation. During the year, Emill earned $2,000,000 of subpart F income. Which of the following statements is true about the application of subpart F to the income earned by Emill?

A Windmill is a CFC and the U.S. corporation and U.S. individual will have a deemed dividend of $1,000,000 and $100,000, respectively.

B Windmill is a CFC and only the U.S. corporation will have a deemed dividend of $1,000,000.

C Windmill is a CFC and the U.S. corporation, U.S. individual, and Swiss corporation will have a deemed dividend of $1,500,000, $100,000, and $900,000, respectively.

D Windmill is not a CFC and none of the shareholders will have a deemed dividend under subpart F.

Which of the following persons should not be treated as a "U.S. shareholder" of a controlled foreign corporation (CFC) for subpart F purposes?

A A U.S. citizen owning 5 percent of the CFC.

B A U.S. citizen owning 15 percent of the CFC.

C A U.S. corporation owning 15 percent of the CFC.

D All of the named persons are U.S. shareholders for subpart F purposes.