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 taxed on receipt of a constructive dividend of $80,000
a. True
b. False
Indicate whether the statement is true or false
True
RATIONALE: U.S. shareholders must include their pro rata share of any Subpart F income.
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