Concept
Subpart F Income 0
Subpart F Income refers to certain types of income earned by controlled foreign corporations (CFCs) that are subject to immediate U.S. taxation, even if not repatriated to the U.S. parent company. This provision aims to curb tax deferral strategies by U.S. shareholders of CFCs by taxing passive and easily movable income streams, such as dividends, interest, and royalties, at the time they are earned abroad.
Relevant Degrees