Peter, Paul and Mary are U.S. citizens and residents and each own 1/3 of the stock of a Costa Rican corporation (CR). In year 1,CR earned $300,000 of interest income and $90,000 of gross income from its tourism business operated in Costa Rica. A. CR is not a CFC because no shareholder owns more than 50% B. Each shareholder must include $100,000 in their U.S. income tax return as foreign personal holding income (FPHC) under subpart F of the internal revenue code C. Each shareholder must include in their U.S. income tax return $130,000 of FPHC income D. The shareholders do not include and of the income in their U.S. income tax returns until distributed as a dividend