Question
Jumper, Incorporated, which has a 21 percent tax rate, owns 40 percent of the stock of a CFC. At the beginning of 2022, Jumpers basis
Jumper, Incorporated, which has a 21 percent tax rate, owns 40 percent of the stock of a CFC. At the beginning of 2022, Jumpers basis in its stock was $660,000. The CFCs 2022 income was $1 million, $800,000 of which was subpart F income. The CFC paid no foreign income tax and distributed no dividends.
Required: In 2023, the CFCs income was $600,000, none of which was subpart F income or GILTI, and it distributed a $300,000 dividend to its shareholders ($120,000 to Jumper). How much of this actual dividend is taxable to Jumper in 2023? Compute Jumpers basis in its CFC stock at the beginning of 2024.
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