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Phoenix, Inc., a U.S.shareholder owns 100% of a CFC from which Phoenix receives a $650,000 distribution.The CFC's E & P is composed of the following amounts.
-$400,000 attributable to previously taxed increases in investment in U.S.property.
-$200,000 attributable to previously taxed Subpart F income.
-$100,000 attributable to other E & P.
Phoenix recognizes a taxable dividend of:
I Proposition
In traditional logic, an "I proposition" is a type of categorical proposition that affirms some, but not all, members of the subject class are members of the predicate class, often structured as "Some S are P."
Explicit Quantifiers
Symbols or phrases in logic that explicitly specify the quantity of subjects to which a statement applies.
Universal
A term referring to concepts, properties, or statements that apply universally, without exceptions.
Particular
In philosophy, an individual object as opposed to a universal quality; distinguished from general or universal by being specific or detailed.
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