A domestic Corporation owns a Controlled Foreign Corporation. In 2018 the Controlled Foreign Corporation earns $100 of foreign base company income and incurs a ($200) loss attributable to activities that

A domestic Corporation owns a Controlled Foreign Corporation. In 2018 the Controlled Foreign Corporation earns $100 of foreign base company income and incurs a ($200) loss attributable to activities that produce General Category Income (IRC sec 904). It also has $200 of foreign personal holding company income. In 2019 Controlled Foreign Corporation has $100 of General Category Income. The Controlled Foreign Corporation has no tangible person property, are the income tax consequences to Domestic Corporation for 2018 and 2019? Use IRC code 951, 954 and 904 as reference. Must be close to 500 words.

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