Question
Gold, Inc., a U.S. corporation, is the sole U.S. shareholder of Silver, Ltd., incorporated in Bermuda. Golds net taxable income for 2020 is $2,000,000. Silvers
Gold, Inc., a U.S. corporation, is the sole U.S. shareholder of Silver, Ltd., incorporated in Bermuda. Gold’s net taxable income for 2020 is $2,000,000. Silver’s net taxable income for 2020 is $1,000,000 which includes $200,000 Subpart F income, $10,000 interest income and $30,000 interest expense. Gold's qualified business asset investment is $5,000,000, and Silver’s qualified business asset investment is $2,000,000 for 2020. Bermuda’s tax rate is 0%. What is Gold’s Section 250 deduction for 2020?
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