How much will a have to report in his 2022 gross income

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Question: For all of 2022, A, a U.S. citizen, owns 8% of a controlled foreign corporation ("CFC") outright. A also owns 20% of another foreign corporation ("FC") which owns 5% of CFC. The balance of FC is owned by a U.S. income tax nonresident alien ("NRA"). The balance of CFC is owned 1% by A's U.S. citizen son ("S") and 86% by A's long-time U.S. income tax resident alien ("RA") friend ("F"). If CFC has 2022 so-called tainted or subpart F income of $500,000, how much will A have to report in his 2022 gross income?

Reference no: EM133382629

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