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USCo owns all of the stock of FCo, a Country X corporation. FCo manufactures widgets in Country Y for sale throughout the world, excluding the

USCo owns all of the stock of FCo, a Country X corporation. FCo manufactures widgets in Country Y for sale throughout the world, excluding the US. The effective tax rate FCo pays in Country X and Y is identical. Is FCo's income Subpart F income?  

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No in this scenario FCos income is not likely to be Subpart F income for US tax purposes Heres why S... blur-text-image

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