Controlled foreign corporation

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Controlled foreign corporation (CFC)

A foreign corporation whose voting stock is more than 50% owned by US stockholders, each of whom owns at least 10% of the voting power.
Copyright © 2012, Campbell R. Harvey. All Rights Reserved.

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.
Farlex Financial Dictionary. © 2012 Farlex, Inc. All Rights Reserved
References in periodicals archive ?
federal taxable income of certain earnings of controlled foreign corporations.
The 100% pledge of the voting equity in controlled foreign corporations, rather than 65%, may result in some upgrades of secured debt instruments and downgrades of unsecured obligations.
These controlled foreign corporations (CFCs) paid $125.2 billion in foreign income taxes on $662.0 billion of earnings and profits (E&P) (less deficit) before income taxes.
Department of the Treasury and the Internal Revenue Service relating to proposed regulations regarding the treatment of foreign base company sales income from property produced under contract manufacturing arrangements and sold by controlled foreign corporations under section 954(d) of the Internal Revenue Code.
persons who are officers, directors, or shareholders of controlled foreign corporations. (For more on preparing Form 5471, see Jacobs and Pasmanik, "Tips for Preparing the Form 5471 for Controlled Foreign Corporations," p.
This measure will permit corporations to access cash from their controlled foreign corporations (CFCs) without having an income inclusion for U.S.
shareholders of partners that are controlled foreign corporations, attempt--through special partnership allocations--to claim foreign tax credits not matched by income subject to U.S.
More than 50 island companies (subsidiaries of major corporations) have switched to another tax code provision (Section 901), known as Controlled Foreign Corporations (CFCs), but not all companies are able to find tax shelter under this provision.
The focus of Subpart F is on controlled foreign corporations, which are defined as having more than 50 percent of their voting power or stock value owned by U.S.
federal taxable income of certain earnings of controlled foreign corporations. The decrease from the previous FY19 tax rate guidance of 21-22% reflects additional clarification around the impact of the GILTI provision, the expected benefit from the foreign-derived intangible income deduction and the actualized impact of the ASU 2016-09 equity compensation deduction in the first quarter.
These controlled foreign corporations (CFCs) paid $69.3 billion in income taxes on $362.2 billion of earnings and profits (E&P) before income taxes.

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