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NOTES 893 Tax Lawyer, Vol. 55, No. 3 NOTE THE APPLICATION OF SUBPART F INCOME TO A DOMESTIC CORPORATION THROUGH A VOTING TRUST AFTER TEXTRON V. COMMISSIONER In Textron, Inc. v. Commissioner,1 the Tax Court addressed whether subpart F income2 of a controlled foreign corporation (CFC) could be taxed to a domestic corporation when the domestic corporation held all of the shares of the CFC in an involuntary voting trust.3 The court held that the CFC’s subpart F income was includable in the domestic...

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