Copp, Inc., a domestic corporation, owns 40% of a CFC that has $50 million of earnings and profits for the current year. Included in that amount is $20 million of Subpart F income. The CFC has been a CFC for the entire year and makes no distributions in the current year. Copp must include in gross income (before any § 78 gross-up):
a. $0.b. $8 million.c. $20 million.d. $50 million.e. Some other amount.