Refer to the facts in the preceding problem. In 2020, the CFC’s income was $600,000, none of which was subpart F income or GILTI, and it distributed a $300,000 dividend to its shareholders ($120,000 to Jumper). How much of this actual dividend is taxable to Jumper in 2020? Compute Jumper’s basis in its CFC stock at the beginning of 2021. 

Data From Preceding Problem.

Jumper Inc., which has a 21 percent tax rate, owns 40 percent of the stock of a CFC. At the beginning of 2019, Jumper’s basis in its stock was $660,000. The CFC’s 2019 income was $1 million, $800,000 of which was subpart F income. The CFC paid no foreign income tax and distributed no dividends.