Page 216 - International Taxation IRS Training Guides

Subpart
F Modifications

and immediate taxation of subpart F
 TCJA retained full
income but enacted certain changes
to these

provisions

 Modification of US
shareholder definition to include a

person who owns at least 10% of the value of the
US
of the foreign corporation (IRC 951(b))
shares

 Eliminates 30-day requirement for
foreign corporation

for uninterrupted period of at least
to constitute CFC

30 days in order for
a US shareholder to have a

current income inclusion (IRC 951(a))

 Repeal of
inclusion of foreign base company oil-

related income (repeal of
IRC 954(g))

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