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    Exam 25: Taxation of International Transactions
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    Kipp, a US
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Kipp, a US

Question 128

Question 128

True/False

Kipp, a U.S.shareholder under the CFC provisions, owns 40% of a CFC.If the CFC's Subpart F income for the taxable year is $200,000, Kipp is not taxed on receipt of a constructive dividend of $80,000 because he doesn't own more than 50% of the CFC.

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