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.

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 ?
Partial filing requirements exist for noncontrolled foreign corporations and for controlled foreign corporations which are not controlled by a single U.S.
Tax Executives Institute appreciates this opportunity to present its views on the December 2008 regulations providing further guidance on 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.
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.
The history of controlled foreign corporations in United States tax law is characterized by reduction of the tax deferral advantages of United States corporations operating businesses overseas through foreign corporations.
Confidential Transactions of Controlled Foreign Corporations
Substantially clarify the application and operation of the indirect participation rules, especially for reporting shareholders of controlled foreign corporations (CFCs).
As will be discussed in Part II of this article, under "foreign corporations," subpart F income is generally passive income or income earned by a controlled foreign corporation (CFC) outside its country of incorporation from certain related-party transactions.
* Eliminate individual filings for each controlled foreign corporation (CFC) and simply include a schedule of CFCs containing key information, including the balance in the E&P and tax pools.
parent that are part of a back-to-back loan arrangement with a controlled foreign corporation (CFC).
A Court of Appeal affirmed (35) that, in calculating the includible portion of controlled foreign corporation subpart F foreign-source income in its water's-edge report, the taxpayer could statutorily exclude dividends paid by certain second-tier subsidiaries to certain first-tier subsidiaries, because they were paid out of unitary income.
The term []United States Shareholder[] means any shareholder described in section 951(b) without regard to whether the foreign corporation is a controlled foreign corporation. Treas.
Congress accorded Treasury authority to treat ICI derived by a foreign person (e.g., a controlled foreign corporation) as domestic source as necessary to prevent manipulation.

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