Page 21 - International Taxation IRS Training Guides

Outbound Anti-Deferral Rules
(Cont’d)

in U.S. property anti-
 The Subpart F and investment

deferral rules
apply to a “U.S. shareholder” who

owns stock
in a “Controlled Foreign Corporation”
(CFC).

>50% (vote or value) owned by U.S.
 CFC:
Shareholders

U.S. person who owns 10% or
 U.S. Shareholder:

more of voting power

 U.S. Shareholder
required to file Form 5471

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