Domestic corporation owns controlled foreign corporation

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A domestic Corporation owns a Controlled Foreign Corporation. In 2018 the Controlled Foreign Corporation earns $100 of foreign base company income and incurs a ($200) loss attributable to activities that produce General Category Income (IRC sec 904). It also has $200 of foreign personal holding company income. In 2019 Controlled Foreign Corporation has $100 of General Category Income. The Controlled Foreign Corporation has no tangible person property, What are the income tax consequences to Domestic Corporation for 2018 and 2019?

Reference no: EM132921649

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