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HKco is a wholly owned Hong Kong subsidiary of USAco, a domestic corporation. USAco sells widgets to HKco, which then resells them to Korean customers.

HKco is a wholly owned Hong Kong subsidiary of USAco, a domestic corporation. USAco sells widgets to HKco, which then resells them to Korean customers. In addition, USAco pays HKco a fee for finding materials in Japan that USAco buys as a component for its widgets. HKco invests all its profits in certificates of deposit at the Bank of Hong Kong. What types of Subpart F income must USAco report as a result of its ownership of Hkco?

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