Page 622 - Large Business IRS Training Guides
P. 622
Net
CFC Tested Income Example
Facts:
• CFC1 has
tested income of
US1
US2
200x.
• CFC2 has
a tested loss of
100x.
50% 50% 100%
Analysis:
net CFC tested income
• US1’s
(50% of 200x).
is 100x
net CFC tested income
• US2’s
CFC1 CFC2
is -0- (50% of 200x and 100%
of <100x>).
Tested income: 200x Tested loss: <100x>
38
