JamCo, a domestic corporation, operates abroad through three wholly$-$owned foreign corporations, JamFor$1,$ JamFor$2,$ and JamFor$3.$ Each entity is organized in a different foreign country. During the current year, JamFor $1$ has total gross income of $$40$ million, including $$800,000$ of interest income that qualifies as foreign personal holding company income, and $$39\mathrm{.}2$ million of gross income from the sale of goods that JamFor $1$ manufactured in its country of incorporation.

JamFor $2$s current year earnings and profits are $$120$ million, which consists of $$160$ million of foreign personal holding company income and a $$40$ million loss from sales of goods that JamFor $2$ manufactured in its country of incorporation.

a$.$ What amount, if any, should JamFor $1$ report as Subpart F income?

b$.$What amount, if any, should JamFor $2$ report as Subpart F income?

Answer rating: 100% (QA)

Subpart F income is a category of income for controlled foreign corporations in the US tax code that ... View the full answer