Subpart F income is passive and certain related-party income of a controlled foreign corporation that U.S. shareholders must include in their own income currently, whether or not it is distributed.
It includes interest, dividends, rents, royalties, and gains of the foreign corporation, and sales or services income routed through related parties. It is computed on Form 5471.
Together with GILTI, it is why owning a profitable foreign company can create U.S. tax before any money comes home. Controlled foreign corporation.
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Definitions are general information, not legal advice, and may not reflect the most recent changes in law.
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