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Copp,Inc.,a domestic corporation,owns 40% of a CFC that has $50 million of earnings and profits for the current year.Included in that amount is $20 million of Subpart F income.The CFC has been a CFC for the entire year and makes no distributions in the current year.Copp must include in gross income (before any § 78 gross-up) :
Environmental Strategies
Approaches adopted by businesses to minimize their ecological footprint and enhance sustainability through processes, products, or services.
Source Reduction
Efforts made to reduce the amount of waste created by altering the design, manufacture, or use of products and materials.
Financial Base
The underlying financial resources or assets that support an individual, organization, or project.
Long Term Contracts
Agreements that extend over a considerable period, typically involving the delivery of goods or services, to secure stable supply, pricing, or partnership terms.
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