QUESTION 30 USCO, a U.S. corporation owns 100% of Forco, a corporation incorporated in Japan where the foreign income ta
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QUESTION 30 USCO, a U.S. corporation owns 100% of Forco, a corporation incorporated in Japan where the foreign income ta
QUESTION 30 USCO, a U.S. corporation owns 100% of Forco, a corporation incorporated in Japan where the foreign income tax rate is 20 percent. Forco was USCO's only foreign controlled foreign corporation. In 2020 USCo had Subpart F income from Forco of $2.5 million. Forco had no other income. On its 2020 corporate income tax return (Form 1120): a. May make a high tax exclusion election and exclude the $2.5 million from its Form 1120. b. Must include the $2.5 million of Subpart F Income on its Form 1120. c. May not make the high tax exclusion election since the Japan tax rate is less than the U.S. tax rate. d. May exclude the Subpart F income from its Form 1120 since it meets the de minimus rule.