DOG, a U.S. corporation, operates abroad through a wholly-owned foreign corporation, Bco3, which is organized in a

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DOG, a U.S. corporation, operates abroad through a wholly-owned foreign corporation, Bco3, which is organized in a different foreign country.

Bco3 owns 100% of Bco4. Bco3 is incorporated in Country P, whereas Bco4 is incorporated in Country Q. During the current year, Bco3 derives $10 million of interest income on a loan to Bco4, and also receives $15 million of dividends from Bco4. Bco4 is engaged in foreign manufacturing activities in Country Q, and all of Bco4’s assets are located in Q. Bco4 has no Subpart F income.

Determine the amount of Subpart F income, if any, that the controlled foreign corporation must report. (please show any calculations and reasoning for your answer)