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Scenario $3$: International Tax Labyrinth

US citizen is a $20\%$ partner in a foreign partnership located in a tax haven.

The partnership generates significant passive income sheltered from US taxation.

The partnership also owns a Controlled Foreign Corporation $($CFC$)$ in another low$-$tax jurisdiction.

Taxpayer has a $$35,000$ NOL carryforward.

Other Income:

Wages: $$150,000$

US$-$based Interest & Dividends: $$3,000$

Itemized Deductions: $$30,000$

Allowable deduction for self$-$employment tax: None

Questions

Analyze the potential for Subpart F Income inclusions from the CFC$.$

Could the partnership income be considered PFIC income?

How, if at all, can the NOL carryforward be used to offset these types of foreign income?

Research the GILTI provisions and how they might apply.