A citizen/ondividuals own 82% of a Canadian corporation. Other shareholders are foreign nationals. What are the US income tax issues arising from such ownership. US shareholders reported accumulated E&P for 2017 tax year. Corporation recorded 2018 operating loss well in excess of prior year accumlated earnings subject to US tax in 2017. For 2019 tax year CFC reported income substantially less than 2018 deficit. Does deficit from 2018 tax year offset 2019 CFC income?