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U.S. individual owns ForCO, a domestic C corporation that owns a CFC. The CFC owns $10 million of tangible property, earns $2 million of tested
U.S. individual owns ForCO, a domestic C corporation that owns a CFC. The CFC owns $10 million of tangible property, earns $2 million of tested income, and pays $200,000 of foreign income taxes.
a. How much, if any, is ForCO GILTI?
b. How much is ForCO U.S. income taxes?
c. Assume the U.S. Individual owns the CFC directly, do your answers to a & b above change? Explain.
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