What is Subpart F income?

Subpart F income is passive or mobile income earned by CFCs that the US taxes currently (without waiting for dividends): FPHCI (foreign personal holding company income like dividends, interest, rents), foreign base company sales income, and foreign base company services income.

What percentage ownership makes a foreign company a CFC?

A foreign corporation is a CFC if US persons each owning 10%+ collectively own more than 50% of vote or value. Under TCJA attribution rules, constructive ownership through partnerships and trusts is included, greatly expanding CFC status.

CFC Subpart F Income Threshold Calculator

Determine whether a controlled foreign corporation (CFC) triggers US Subpart F income inclusion for its US shareholders: passive income > the lesser of 5% of gross income or $1M. Applies IRC §§ 951–965.

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⚖ For informational purposes only. Not legal advice. Consult a licensed attorney for your specific situation.

How to Use

Enter the values for the scenario you are assessing. Determine whether a controlled foreign corporation (CFC) triggers US Subpart F income inclusion for its US shareholders: passive income > the lesser of 5% of gross income or $1M. Applies IRC §§ 951–965. Use the subpart f cfc income result to inform your calculation.

CFC Subpart F Income Threshold Calculator

Statute of Limitations

How to Use

Frequently Asked Questions

What is Subpart F income?

What percentage ownership makes a foreign company a CFC?