During the current year, Fco1 has total gross income of $10 million, including $400,000 of interest income that qualifies as foreign personal holding company income, and $9.6 million of gross income from the sale of goods that Fco1 manufactured in its country of incorporation.
Fco2’s current year earnings and profits are $30 million, which consists of $40 million of foreign personal holding company income and a $10 million loss from sales of goods that Fco2 manufactured in its country of incorporation.
Fco3 owns 100% of Fco4. Fco3 is incorporated in Country P, whereas Fco4 is incorporated in Country Q. During the current year, Fco3 derives $10 million of interest income on a loan to Fco4, and also receives $15 million of dividends from Fco4. Fco4 is engaged in foreign manufacturing activities in Country Q, and all of Fco4’s assets are located in Q. Fco4 has no Subpart F income.
Determine the amount of Subpart F income, if any, that each controlled foreign corporation must report; break up answers by subparts.