Question

Windmill Corporation,a Dutch corporation,is owned by the following unrelated persons: 50 percent by a U.S.corporation,5 percent by a U.S.individual,and 45 percent by a Swiss corporation.During the year,Windmill earned $2,000,000 of subpart F income.Which of the following statements is true about the application of subpart F to the income earned by Windmill?
A) Windmill is a CFC and the U.S. corporation and U.S. individual will have a deemed dividend of $1,000,000 and $100,000, respectively.
B) Windmill is a CFC and only the U.S. corporation will have a deemed dividend of $1,000,000.
C) Windmill is a CFC and the U.S. corporation, U.S. individual, and Swiss corporation will have a deemed dividend of $1,500,000, $100,000, and $900,000, respectively.
D) Windmill is not a CFC and none of the shareholders will have a deemed dividend under subpart F.

Answer 1

Answer: Windmill is not a CFC and none of the shareholders will have a deemed dividend under subpart F.

Explanation:

Subpart F income include insurance income, illegal bribes, foreign base company income, international boycott factor income, etc.

It should be noted that Windmill isn't a controlled foreign corporation that is the company isn't a corporate entity which is duly registered and then conducts business in another country that's different from its home country. Therefore, none of the shareholders will have a deemed dividend under subpart F.