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Unreported Foreign Passive Income? Streamlined Filing May Help Resolve Subpart F Exposure.
Subpart F income (passive and certain other categories of CFC income) is taxed to U.S. shareholders in the year the CFC earns it, regardless of whether any distribution is made. The categories include foreign personal holding company income (dividends, interest, rents, royalties), foreign base company sales and services income, and insurance income under IRC Sections