U.S. Taxation of Multinational Transactions

Question 1

IRC Subpart F income

Answer 1

includes foreign base company income by a controlled foreign corporation (CFC)

Question 2

If a CFC is deemed to have Subpart F income

Answer 2

that income may need to be currently included in the U.S. parent’s taxable income if there are not enough exceptions or deductions to reduce the Subpart F income to zero