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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