Question 1:

Plan B, a domestic corporation, received $250,000 from its wholly owned CFC with a functional currency other than the USD, all income from which has been reported in prior years as subpart F income.

Determine the following:

A.) Is the $250,000 U.S. source income or foreign source income?

B.) what is the reasoning for determination of part A?

C.) provide necessary code section/regulation to support determination.