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For the following two independent scenarios, briefly explain how much, if any, constructive dividends the domestic corporation must recognize in the current year. Briefly explain

For the following two independent scenarios, briefly explain how much, if any, constructive dividends the domestic corporation must recognize in the current year. Briefly explain your responses (A) USP1, a domestic corporation, operates abroad through a wholly-owned foreign corporation, Fco1. During the current year, Fco1 has total gross income of $10 million, including $900,000 of interest income received from Fco2 (a related CFC that operates an active business in Country 2 and has no Subpart F income) and $9.1 million of interest and dividends from investments in unrelated companies. How would your response above change if the facts were reversed and Fco1 received $9.1 million of interest income from Fco2 (a related CFC that operates an active business in Country 2 and has no Subpart F income) and $900,000 of interest and dividends from investments in unrelated companies. Briefly explain your response.

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