What is a controlled foreign corporation?
Tax Professional Answers
Code section 951(b) defines a U.S. shareholder as any U.S. person who owns 10% or more of the total combined voting power of all classes of stock of the foreign corporation.
Indirect ownership, in general, consists of stock beneficially owned by a U.S. person through a foreign corporation, partnership, trust and estate. I.R.C. § 958(a)(2).
In general, constructive ownership treats stock owned by an individual as owned by his or her spouse, children, grandchildren and parents. I.R.C. § 318.
Tax Questions By Topic:
Meet Leading Tax Advisors
Bossier City, Louisiana, USA
Enrolled Agent, Master Tax Advisor
New York, New York, USA
Federal Tax Credits & Incentives Practice Leader
Lakeland, Florida, USA
Denver, Colorado, USA
Fullerton, California, USA
Sanford, Florida, USA
Topanga, California, USA
Greenville, South Carolina, USA
Edina, Minnesota, USA
Santa Clara, California, USA
Tax Principal - President
Chattanooga, Tennessee, USA
Stellenbosch, South Africa
Exchange Control & Master Tax Practitioner (SA)
Boston, Massachusetts, USA
Tax Partner, International Tax
Toronto Mississauga Oakville Burlington Hamilton, Canada
West Palm Beach, Florida, USA