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Which of the following statements is correct with respect to the earnings and profits ( E&P ) limitation on Subpart F income of a controlled
Which of the following statements is correct with respect to the earnings and profits E&P limitation on Subpart F income of a controlled foreign corporation CFC
a If a category of Subpart F income or foreign base company income FBCI is reduced because of the E&P limitation such amount becomes a potential recapture amount in a subsequent year
b The CFCs Subpart F income for any tax year is the amount of that Subpart F income irrespective of the E&P of the CFC
c The foreign tax credit limitation categories do not play an important part in the E&P limitaion on subpart F income and potential subsequent recapture
d Where a CFCs Subpart F income exceeds its E&P for the tax year, the excess reduces all Subpart F income on a prorata basis
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