Under the context of controlled foreign corporations, a U.S. shareholder is defined as a U.S. Person who owns or is considered as owning 10% or more of the total combined voting power of all classes of stock entitled to vote of a foreign corporation.  Does this language mean that constructive ownership is considered when determining...Read More

Subpart F of the Internal Revenue Code deals with controlled foreign corporations (sometimes referred to as a CFC), and does not necessarily apply to every United States person or business entity that owns stock in a foreign corporation.  Subpart F applies to United States shareholders of controlled foreign corporations.  See Internal Revenue Code Section 951(a). ...Read More