In which of the following cases are the U.S. shareholders in a controlled foreign corporation (CFC) avoiding U.S. tax on the CFC's income?
A. The CFC operates in a jurisdiction with a tax rate lower than the U.S. rate, has no subpart F income, and 100% of its income is global-intangible low-taxed income.
B. The CFC operates in a jurisdiction with a tax rate lower than the U.S. rate, and 100% of the CFC's income is subpart F income.
C. The CFC operates in a jurisdiction with a tax rate lower than the U.S. rate, has no subpart F or global intangible low-taxed income, and pays no dividends.
D. The CFC operates in a jurisdiction with a tax rate lower than the U.S. rate; 50% of its income is subpart F income and 50% is global intangible low-taxed income.
Answer: C
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