Subpart F Income Earned by a CFC Will Always Be

question 77

True/False

Subpart F income earned by a CFC will always be treated as a deemed dividend to the CFC's U.S. shareholders in the year the subpart F income is earned.
The subpart F income could be excluded from being a deemed dividend under a de minimis rule if the gross amount of the income is less than the lesser of $1 million or five percent of gross income.

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Definitions:

Union Density

Represents the percentage of workers in a specific sector or country that are members of labor unions.

U.S. Union

Labor organizations in the United States that represent the collective interests of workers in various industries and advocate for their rights.

Private and Public Sectors

The division of the economy into two parts; the private sector involves businesses owned by individuals or companies, and the public sector involves organizations owned and operated by the government.

Union Density

The ratio of unionized workers to the total number of workers, indicating the prevalence of union membership within a particular labor market.