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The de minimis rule allows a taxpayer to disregard foreign base company income and adjusted gross insurance income if wh...

The de minimis rule allows a taxpayer to disregard foreign base company income and adjusted gross insurance income if which of the following conditions is satisfied?

A) Either one is less than $10 million or 15 percent of the corporation's gross income

B) The combined total of the two is less than $5 million or 1 percent of gross income

C) The combination of the two is less than the lesser of $1 million or 5 percent of the CFC's gross income

D) The combined total of the two is less than the greater of $1 million or 10 percent of gross income

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Answer #1

If the sum of foreign base company income and the gross insurance income for the taxable year is less than the lesser of—

(i)

5 per cent of gross income, or

(ii)

$1,000,000,

no part of the gross income for the taxable year shall be treated as foreign base company income or insurance income.

Thus the answer is:

C) The combination of the two is less than the lesser of $1 million or 5 percent of the CFC's gross income

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