
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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