The different categories of Subpart F income must be computed separately. U.S. shareholders of a CFC are restricted in how they compute their income and losses. In particular, they are required to compute their Subpart F income separately. Thus, a loss from base company sales income may not offset a gain from foreign base services income.

March 25, 2014
Subpart F Income Requires Separate Computations

Subpart F Income Requires Separate Computations

The different categories of Subpart F income must be computed separately. U.S. shareholders of a CFC are restricted in how they compute their income and losses. […]