Subpart F CFC Income Calculator
Subpart F income forces US shareholders of Controlled Foreign Corporations (CFCs) to pay US tax on certain passive and base-company income — even if the cash stays in the foreign subsidiary. Calculate your inclusion and tax.
| FPHCI | — |
| FBCI (sales/services) | — |
| Other Subpart F | — |
| Total CFC Subpart F income | — |
| Your pro-rata share (ownership %) | — |
| Less: high-tax exclusion (>90% US rate) | — |
| Net Subpart F inclusion | — |
| US tax + foreign tax credit | — |
Subpart F (IRC §§951-964) requires US shareholders of Controlled Foreign Corporations (CFCs) to pay current US tax on certain passive and base-company income — even if the cash stays in the foreign subsidiary. This is anti-deferral legislation enacted in 1962 to prevent US shareholders from sheltering passive income in low-tax jurisdictions.
Who's a US Shareholder / CFC
US Shareholder: US person owning ≥10% voting power of a foreign corporation. CFC: foreign corporation with US shareholders owning >50% combined. If you're a US Shareholder of a CFC, you must include your pro-rata share of Subpart F income on your US return — regardless of distribution.
Categories of Subpart F
(1) FPHCI: Foreign Personal Holding Company Income — passive income including dividends, interest, royalties, rents, capital gains. (2) FBCSI: Foreign Base Company Sales/Services Income — sales/services between related parties where neither manufacture nor consumption is in CFC's country. (3) Insurance income. (4) Boycott income.
High-Tax Exclusion
If the foreign tax rate on a particular CFC's tested income exceeds 90% of the US corporate rate (currently 21% × 90% = 18.9%), the C-corporation US shareholder can elect to exclude that income from Subpart F. Saves US tax — but locks you out of the foreign tax credit on that income. Election made annually on Form 5471.
Last updated May 2026. Sources: IRS CFC Overview, IRS Form 5471.