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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?
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A psychologist known for his theory on the psychosocial development of human beings.
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A trait or quality deemed to be morally good and thus is valued as a foundation of principle and good moral being.
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Physical touch or connection between individuals, important for emotional bonding and development in humans.
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