For the following two independent scenarios, briefly explain how much, if any, constructive dividends the domestic corporation must recognize in the current year. Briefly explain your responses (A) USP1, a domestic corporation, operates abroad through a wholly-owned foreign corporation, Fco1. During the current year, Fco1 has total gross income of $10 million, including $900,000 of interest income received from Fco2 (a related CFC that operates an active business in Country 2 and has no Subpart F income) and $9.1 million of interest and dividends from investments in unrelated companies. How would your response above change if the facts were reversed and Fco1 received $9.1 million of interest income from Fco2 (a related CFC that operates an active business in Country 2 and has no Subpart F income) and $900,000 of interest and dividends from investments in unrelated companies. Briefly explain your response.

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A In the first scenario Fco1 has total gross income of 10 million including 900000 of interest incom... View the full answer