Page 603 - Large Business IRS Training Guides
P. 603
GILTI and Domestic
Partnerships 1
• A domestic partnership is treated as owning stock of a
foreign corporation within the meaning of §958(a) only to
determine the following:
whether any US person is a US shareholder,
(1)
(2) whether any US shareholder is a controlling domestic
shareholder, or
(3)
whether any foreign corporation is a CFC.
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