Page 218 - International Taxation IRS Training Guides
P. 218
Subpart
F Modifications:
Downward Attribution
FP is a widely
held foreign corporation with no 10% direct or indirect US
shareholders. The remaining 10% of
FP owns 100% of USC1 and 90% of FC.
an unrelated US shareholder.
FC is owned by
Before TCJA, FC would not be a CFC. Under TCJA, FC is treated as a CFC.
Foreign
100%
Shareholders
FP USC2
100% 90% 10%
USC1 FC
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