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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 are intended for use or consumption within Country X and have the same gross profit.Sixty percent of the widgets were sold through a Country X wholesaler that is 100% owned by Phoenix,and 40% are sold through unrelated Country X wholesalers.What amount of profits will be constructively distributed as foreign-base company sales income to the U.S.parent company?
Torture
The act of inflicting severe pain or suffering on someone, typically to punish or coerce them into a particular action or confession.
Doctrine of Preemptive War
A theory that suggests a state can launch a war in anticipation of immediate aggression from another state.
WTO's Dispute Settlement Board
An entity within the World Trade Organization that deals with disputes between member countries regarding the interpretation and application of the WTO agreements.
Uruguay Round Agreements
A series of international trade agreements concluded in 1994, which established the World Trade Organization and aimed to reduce trade barriers worldwide.
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