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In 2017, Phoenix Corporation is a controlled foreign corporation (CFC) incorporated in Country X. It is 100% owned by its U.S. parent corporation. Phoenix has $80,000 of taxable income from the sale of widgets that were purchased from their U.S. parent corporation. All widgets are intended for use or consumption within Country X and have the same gross profit. Sixty percent of the widgets were sold through a Country X wholesaler that is 100% owned by Phoenix, and 40% are sold through unrelated Country X wholesalers. What amount of profits will be constructively distributed as foreign-based company sales income to the U.S. parent company?
Economic Efficiency
A state where resources are allocated in a way that maximizes the production of goods and services at the lowest cost.
Costs
represent the total expenditures required to produce a good or service, including materials, labor, and overhead.
Benefits
Advantages or payments made to employees or members of insurance or social welfare programs.
Government Functions
The activities and responsibilities undertaken by a government, including legislation, law enforcement, and the provision of public goods and services.
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