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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 have the same gross profit. Sixty percent of the widgets were sold through a Country Y wholesaler that is 100% owned by Phoenix, and are destined for use in Country Y. The remaining 40% are sold through unrelated Country X wholesalers and are destined for use in Country X. What amount of profits will be constructively distributed as foreign-based company sales income to the U.S. parent company?
Statement of Defence
A formal document filed by the defendant in a lawsuit detailing their defenses or objections to the claims made in the statement of claim.
General Partner
In a partnership, a member who has unlimited liability for the debts of the business and takes part in its management.
Limited Partner
An investor in a partnership who has limited liability to the extent of their investment and does not take part in the day-to-day management of the business.
Letterhead
The heading at the top of a sheet of letter paper, usually consisting of a name and an address, and often a logo.
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