CFC

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CFC

Controlled Foreign Corporation

A company registered in and regulated by a foreign country that has at least 50% American ownership. Setting up a corporation in a foreign country may have tax advantages; for example, a country may encourage companies to register in it by having no corporate tax. The IRS works within the context of foreign treaties to determine how earnings from controlled foreign corporations are taxed in the United States.
References in periodicals archive ?
Both CFC 1 and CFC 3 apply the Section 163(j) limitation to business interest expense (BIE) as if they were standalone U.S.
(32) For purposes of these rules, the proposed regulations use the statutory formula to allocate the GILTI inclusion amount back to individual CFCs, with tested income taken into account in determining a U.S.
For Tax Year 2008, CFCs engaged in finance, insurance, real estate, and rental and leasing held 46.4 percent of all assets while generating only 11.6 percent of the total receipts and 8.5 percent of the E&P (less deficit) before income taxes reported by all CFCs.
A branch is treated as a manufacturing branch where a CFC carries on manufacturing activities by or through a branch located outside the CFC's country of incorporation and the remainder of the CFC purchases or sells the personal property.
Luege said the move to halt production of CFCs demonstrates Mexico's commitment to international conventions to protect the environment.
In the 1970s, scientists first discovered that CFCs and other chemicals could damage the Earth's protective ozone layer, which shields life on Earth from the harmful effects of ultraviolet (UV) radiation.
The project, along with similar ones undertaken by the World Bank in China and Russia, will help phase out more than 80% of the remaining global CFC production.
Cheap, foreign-made CFCs provide an easy "fix" for consumers reliant on outdated technologies.
The seven Russian CFC factories named by the UN environment watchdog are believed to be the principle source of the estimated 30,000 tonnes of CFCs illegally traded in the Western world.
Recycled CFCs are legal, Bocksaid,but the smuggling activity has made recycling and cleaning of used CFCs unprofitable.
The major manufacturers had voluntarily agreed to phase-out the most widely used CFCs, those known as R-11 and R-12, long before the legal phaseout date.
Ray went on to insist that there was little likelihood that freons (chlorofluoro-carbons, or CFCs for short) would reach the stratosphere.