Piper, a US citizen owns 100% of the stock of FORco, a foreign manufacturing and sales subsidiary. In 2020, FORco had $10 million of income from the manufacturing and sale of widgets in Europe and paid $3 million in foreign income taxes. FORco distributed no dividends. In January of 2020, FORco invested/deposited $7 million with a US Bank earning 1% annual interest (US sourced income). What are the U. S. tax consequences (if any) to Piper?
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Piper, a US citizen owns 100% of the stock of FORco, a foreign manufacturing and sales subsidiary. I...
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