Windmill Corporation, a Dutch Corporation, Is Owned by the Following

question 37

Multiple Choice

Windmill Corporation, a Dutch corporation, is owned by the following unrelated persons: 50 percent by a U.S. corporation, 5 percent by a U.S. individual, and 45 percent by a Swiss corporation. During the year, Windmill earned $2,000,000 of subpart F income. Which of the following statements is true about the application of subpart F to the income earned by Windmill?

• A)Windmill is a CFC and the U.S. corporation and U.S. individual will have a deemed dividend of $1,000,000 and $100,000, respectively.
• B)Windmill is a CFC and only the U.S. corporation will have a deemed dividend of $1,000,000.
• C)Windmill is a CFC and the U.S. corporation, U.S. individual, and Swiss corporation will have a deemed dividend of $1,500,000, $100,000, and $900,000, respectively.
• D)Windmill is not a CFC and none of the shareholders will have a deemed dividend under subpart F.

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Definitions:

Short-Term Memory

Short-term memory is a cognitive system with a limited capacity that is responsible for temporarily holding information available for processing.

Baddeley and Hitch

Psychologists who proposed the model of working memory, explaining how the brain processes and stores short-term information.

Atkinson and Shiffrin

Psychologists who proposed the multi-store model of memory, which includes the sensory register, short-term memory, and long-term memory.

Memory Storage

The process of retaining information over time, which is critical for learning, decision-making, and personal identity.