Round, Inc., a U.S. corporation, owns 80% of the only class of stock of Square, Inc., a CFC. Square is a CFC until October 1 of the current tax year (not a leap year). Round has held the stock since Square was organized and continues to hold it for the entire year. Round and Square are both calendar year taxpayers.
Square's Subpart F income for the tax year is $5 million, current E & P is $12.5 million, and no distributions have been made for the tax year. What amount, if any, must Round include in gross income under Subpart F for the tax year?