How much of EuroHealth’s income is Subpart F income? How much of BelHealth’s income is Subpart F income? How much of LuxHealth’s income is Subpart F income? What is the total amount of Subpart F income that HealthWest must include as income in the current year?
HealthWest, a US Corporation owns 100% of EuroHealth, a Luxembourg holding corporation. EuroHealth is a holding company and does not conduct any business activities. EuroHealth owns 100% of two subsidiaries: BelHealth, a Belgian corporation, and LuxHealth, a Luxembourg corporation. EuroHealth’s only assets are shares of its two subsidiaries. EuroHealth’s only income is dividend payments from its subsidiaries of $120 each. LuxHealth buys exercise equipment manufactured by HealthWest and sells it in France and the Netherlands and realizes a gain of $500 on the sale of the equipment. BelHealth purchases exercise equipment from HealthWest and sells it in Belgium and realizes a gain of $400 on the sale of the equipment.
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