Question
Which of the following incomes earned by a controlled foreign corporation incorporated in Spain is not foreign personal holding company income? A Interest income received
Which of the following incomes earned by a controlled foreign corporation incorporated in Spain is not foreign personal holding company income?
A Interest income received from a loan to an unrelated party.
B Dividend income from a 5 percent investment in an unrelated corporation.
C Rent received from a passive investment in an apartment complex.
D Gross profit from the manufacture and sale of inventory to an unrelated party.
Rang Corporation, a Newfoundland corporation, is owned by the following unrelated persons: 40 percent by a U.S. corporation, 15 percent by a U.S. individual, and 45 percent by an Australian corporation. During the year, Rang earned $3,000,000 of subpart F income. Which of the following statements is true about the application of subpart F to the income earned by Rang?
A Rang is a CFC and the U.S. corporation and U.S. individual will have a deemed dividend of $1,200,000 and $450,000, respectively.
B Rang is a CFC and only the U.S. corporation will have a deemed dividend of $1,200,000.
C Rang is a CFC and the U.S. corporation, U.S. individual, and Australian corporation will have a deemed dividend of $1,200,000, $450,000, and $1,350,000, respectively.
D Rang is not a CFC and none of the shareholders will have a deemed dividend under subpart F.
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