1. 163 J: Business Interest Expense limitation: Example: Capital Structure: Debt - 98% Equity - 2% 8890 Fedra Form Why IRS limiting a corporation? Corporation highly leverage on debt so they pay high interest expense to claim deductions. 2. Sec 78 Gross up: If parent paid taxes of it's foreign subsidiaries, then the parent Can Claim that tax in us and can pay less tax Ex. 100$ (CFC) earn & paid 10$ tax & in Us parent must 21% 21$ pay can deduct 10$, must pay only 11$. line 30 state 50% deduction line 28 State 100% deduction $210 $ 10 = $ 11 3. Sub part F: If Sub part f is an income which is relatively movable from one taxing jurisdiction to another and that is Subject to low rates of foreign tax - This applies to CFC only. 4. DRD: Dividend Received Deduction It is a tax deduction available to corporations in the US that receive dividen...