Shamrock Limited $($Shamrock$)$ is an Irish incorporated, non$-$publicly traded entity, which was formed in January $2022,$ and treated as a foreign corporation with a calendar year end for U$.$S$.$ tax purposes. Shamrock has $10,000$ shares of voting common stock outstanding. Shamrock has no other outstanding or authorized stock. ABC, Inc., a U$.$S$.$ C$-$Corporation with a calendar year end, owns $8,000$ shares of Shamrock. Patrick, a U$.$S$.$ citizen, owns $750$ shares of Shamrock, and neither he nor any related person holds shares, directly or indirectly, in ABC, Inc. The remaining $1,250$ shares of Shamrock are owned by a United Kingdom $($UK$)$ corporation, Cheers Limited, which holds no shares, directly or indirectly, in ABC, Inc. Cheers Limited has $1,000$ shares of a single class of common stock outstanding, which are all owned by a UK individual, Nigel, who is unrelated to Patrick, and neither he nor a related person holds shares, directly or indirectly, in ABC, Inc.

Part A:

Shamrock purchases widgets, which are manufactured by ABC, Inc. in the United States, and sells twenty percent $(20\%)$ of them to unrelated customers in Ireland and eighty percent $(80\%)$ of them to unrelated customers outside of Ireland. In calendar year $2022,$ Shamrock generated $$10,000,000$ of gross income from the sale of widgets purchased from ABC, Inc. Of the $$10,000,000$ of gross sales income, $$2,000,000$ was generated from the Irish sales, while the remaining $$8,000,000$ was from sales generated outside of Ireland. For simplicity purposes, assume that Shamrock had no allowable deductions for the calendar year with respect to this gross sales income. Therefore, Ireland levied a corporate income tax at a flat rate of fifteen percent $(15\%)$ on the gross sales income generated by Shamrock $-$ i$.$e$.,$ Irish Corporate Income Tax: $$1,500,000[$Gross Sales Income: $$10,000,000*15\%].$

$($a$.)$ Is Shamrock a controlled foreign corporation $($CFC$)$ for the current year? Please explain.

$($b$.)$ In calendar year $2022,$ do any of the Shamrock shareholders have a Subpart F income inclusion? If so$,$ please identify the type of Subpart F income, the amount of each shareholder$$s Subpart F income inclusion, if any, and the associated U$.$S$.$ tax consequences, as well as how the inclusion will be $$basketed$$ for foreign tax credit limitation purposes, if applicable. For purposes of this question, assume a flat U$.$S$.$ corporate income tax rate of $21\%.$ Also, assume that no deductible U$.$S$.-$based expenses would be allocated and apportioned against any Subpart F income inclusion and ignore the Global Intangible Low$-$Taxed Income $($GILTI$)$ rules. Please explain.

$($c$.)$ In calendar year $2023,$ Shamrock broke$-$even $$ i$.$e$.,$ generated no current year earnings and profits $($E&P$),$ paid no foreign income taxes, and declared & paid an $$8,500,000$ dividend pro$-$rata to its shareholders on December $31,2023,$ which was not subject to an Irish dividend withholding tax. Assuming a flat U$.$S$.$ corporate income tax rate of $21\%,$ what are the U$.$S$.$ tax consequences to each shareholder. Also, assume that the United States has entered into a bilateral income tax treaty with Ireland.