Berger Is a Controlled Foreign Corporation with $2 Million of Subpart

question 49

Multiple Choice

Berger is a controlled foreign corporation with $2 million of subpart F income and $3.5 million of global intangible low-taxed income. Salter, Inc., a U.S. corporation, owns 100% of Berger's stock. Compute Salter's incremental U.S. tax liability (before credits) resulting from its ownership of Berger.

• A) $1,155,000
• B) $477,500
• C) $787,500
• D) $0

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