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Tag Archive for Section 318

United States CFC Rules: What Is A United States Shareholder?

Like most subparts in the United States tax code (the CFC rules are a sub-part to sub-chapter N in the code), the CFC rules have specific concepts and definitions that apply only to this particular sub-part. The most important definition is that of a “US shareholder.” In addition, like most sections in the code, the CFC rules require us to reference multiple sections to get a complete definition.

Let’s start with section 957, which states:

For purposes of this subpart, the term “controlled foreign corporation” means any foreign corporation if more than 50 percent of— Read more

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