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USC, a domestic corporation, operates abroad through three wholly-owned foreign corporations, Forco1 through Forco3, each of which is organized in a different foreign country. During
- USC, a domestic corporation, operates abroad through three wholly-owned foreign corporations, Forco1 through Forco3, each of which is organized in a different foreign country. During the current year, Forco1 has total gross income of $10 million, including $400,000 of interest income that qualifies as foreign personal holding company income, and $9.6 million of gross income from the sale of goods that Forco1 manufactured in its country of incorporation. Forco2's current year earnings and profits are $30 million, which consists of $40 million of foreign personal holding company income and a $10 million loss from sales of goods that Forco2 manufactured in its country of incorporation.
- What amount, if any, should Forco1 report as Subpart F income?
- What amount, if any, should Forco2 report as Subpart F income?
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