What is Subpart F income and how does it apply to foreign-owned business structures?
I've been reading about Subpart F income in the context of CFC rules and I'm confused about how it fits in with GILTI. I'm a U.S. citizen running a business through a foreign corporation. Some of the corporation's income seems to fall into Subpart F categories. Can someone explain what Subpart F actually covers, why it was created, and how it differs from GILTI? I want to understand the full picture of how my foreign corporation's income gets taxed.
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