LO.3 Ames, Inc., a U.S. corporation, owns 100% of Boone, Ltd., a United Kingdom corporation. Boone purchases finished inventory from Ames and sells the inventory to customers in the U.K. and Germany. During the current year, Ames earned $600,000 in profits from sales to U.K. customers and $400,000 in profits from sales to German customers. Boone operates a sales office in London with 12 full-time employees. How much of Boone’s $1 million in profits will be characterized as Subpart F income?