Glossary · Entity & Business
Subpart F Income
Subpart F is an older US anti-deferral regime that taxes US owners currently on certain passive or mobile income of a controlled foreign corporation, regardless of distribution. It operates alongside GILTI/NCTI.
In more detail
Subpart F targets specific categories — mainly passive income (dividends, interest, rents, royalties) and certain related-party sales/services income — earned inside a CFC, taxing the US owner immediately. It predates GILTI and still applies; together they form the US framework for taxing a US-owned UK company profits before they are paid out.
Does Subpart F Income apply to your situation?
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