What is the rationale for excluding Subpart F income from the definition of net tested income? Group of answer choices Subpart F is only earned by CFCs and net tested income excludes all income earned by CFCs There is no rationale for this because Subpart F is NOT excluded from the definition of net tested income. Subpart F income is already treated as a constructive dividend so including it in GILTI would be double counting Subpart F income is foreign source income and net tested income is intended to capture US source income only

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The rationale for excluding Subpart F income from the definition of net tested income is Subpart F i... View the full answer