Foreign personal holding company income. Foreign personal holding company income is further broken down into the following categories. Dividends, interest, rents, royalties and annuities. Gains from certain property transactions. Gains from commodities transactions.
Foreign currency gains over losses.
Income equivalent to interest. The application of the high tax exception to passive foreign personal holding company income is subject to a consistency rule. If an election is made to exclude an item of passive foreign personal holding company income from subpart F income under the high tax exception, the election must be consistently made with respect to all items of passive foreign personal holding company income eligible to be excluded. For example, all service income received by a CFC is treated as a single item of income for purposes of this rule regardless of whether the income is earned in more than one foreign country. Foe Corporation is a CFC operating in Italy.