Windmill Corporation, a Dutch corporation, is owned by the following unrelated persons: $50$ percent by a U$.$S$.$ corporation, $5$ percent by a U$.$S$.$ individual, and $45$ percent by a Swiss corporation. During the year, Windmill earned $$2,000,000$ of subpart F income. Which of the following statements is true about the application of subpart $F$ to the income earned by Windmill?