Question

Togo Inc. has a subsidiary incorporated in Country H, which does not have a corporate income tax. Which of the following activities generates subpart F income?
a. The subsidiary buys woolen clothing products manufactured by a Swedish company and sells the products to unrelated wholesalers in the United States. Togo owns the Swedish company.
b. The subsidiary buys coffee beans grown on plantations located in Country H and sells the beans to Togo, which makes coffee products.
c. The subsidiary buys building materials from a Mexican company and sells the materials to construction companies operating in Country H. Togo owns the Mexican company.


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  • CreatedNovember 03, 2015
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