Tiger, Inc., owns 81% of the only class of stock for a CFC named Wolf, Inc. Wolf, Inc. is based in Germany, and Tiger, Inc. is a US corporation. Both are calendar-year taxpayers and Tiger, Inc. has held stock in Wolf, Inc. since its inception. Wolf, Inc.’s Subpart F income for the current tax year is $1,100,000, the Current E&P is $3,100,000, and no distributions have been made this year.

Calculate the amount of Subpart F income that Tiger, Inc will need to include it its gross income for the year.

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