Wellington, Inc., a U.S. corporation, owns 100% of a CFC that has $50 million of income in the current year. Included in that amount is $20 million of Subpart F income. Wellington has owned the CFC for the entire year during which the CFC makes no distributions. Wellington must include in gross income (before any 78 gross-up):

Group of answer choices

$0

$20 million

$50 million

None of the above