Page 600 - Large Business IRS Training Guides
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Controlled Foreign Corporation 1
• A CFC is any foreign corporation in which more than 50%
of the vote or value is owned, directly, indirectly, or
constructively, by US shareholders. §957(a).
• §958(a) has
rules regarding direct and indirect (through
foreign entities) ownership.
has rules regarding constructive ownership.
• §958(b)
• TCJA repealed §958(b)(4).
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