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USCo, a US corporation, owns 100% of the stock of FSub1, a foreign corporation. In 20X1, FSub1 earns $500 of interest income (which is FPHCI)
USCo, a US corporation, owns 100% of the stock of FSub1, a foreign corporation. In 20X1, FSub1 earns $500 of interest income (which is FPHCI) and $100 of active business income. None of its income was subject to foreign income tax.
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Federal Taxation 2016 Comprehensive
Authors: Thomas R. Pope, Timothy J. Rupert, Kenneth E. Anderson
29th Edition
134104374, 978-0134104379
