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USA, Inc., a domestic C - Corporation, operates abroad through four ( 4 ) wholly - owned foreign corporations, Fco 1 , Fco 2 ,
USA, Inc., a domestic CCorporation, operates abroad through four whollyowned foreign corporations, Fco Fco and Fco which it owns directly, and Fco which it owns indirectly via Fco each of which is organized in a different foreign country.
During the current year, Fco has total gross income of $ including $ of interest income that qualifies as foreign personal holding company income, and $ of gross income from the sale of goods that Fco manufactured in its country of incorporation.
Fcos current year earnings and profits are $ which consists of $ of foreign personal holding company income and a $ loss from sales of goods that Fco manufactured in its country of incorporation.
As mentioned above, Fco is a whollyowned subsidiary of Fco Fco is incorporated in Country P whereas Fco is incorporated in Country Q During the current year, Fco derives $ of interest income on a loan to Fco and also receives $ of dividends from Fco Fco is engaged in foreign manufacturing activities in Country Q and all of Fcos assets are located in Q Fco has no Subpart F income.
Determine the amount of Subpart F income, if any, each of the four controlled foreign corporations must report.
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