Page 698 - Large Business IRS Training Guides
P. 698
Who is Subject
to Section 965?
shareholder (as defined in section 951(b))
• Any U.S.
indirectly owns the stock of a
that directly or
specified foreign corporation (“SFC”) within the
section 958(a) (“section 958(a) U.S.
meaning of
shareholder”).
• For purposes of section 965, a U.S. shareholder is a
U.S. person that owns 10% of the voting power of a
foreign corporation.
• If a domestic pass-through entity is a section 958(a)
U.S. shareholder of an SFC, the domestic pass-
through owners are subject to section 965.
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