BioTech, Inc. owns 60% of the stock of Aachen Laboratories, GmbH, a corporation organized in Germany. Aachen

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Question:

BioTech, Inc. owns 60% of the stock of Aachen Laboratories, GmbH, a corporation organized in Germany. Aachen Laboratories, GmbH owns 70% of Dresden Scientific, GmbH, a corporation organized in Germany.

a. State the foreign corporations that are considered controlled foreign corporations for purposes of subpart F as defined by section 957(a) and applying the constructive ownership rules of section 958(b).

b. State the pro rata share of subpart F income recognized by BioTech, Inc., if any, if Aachen Laboratories, GmbH earned foreign base company sales income of 10 million.

c. State the pro rata share of subpart F income recognized by BioTech, Inc., if any, if Dresden Scientific, GmbH earned foreign base company sales income of 10 million.