Contributing editor Robert Willens, founder and principal of Robert Willens LLC, writes a weekly tax column for CFO.com.
Footnotes
1 A CFC is any foreign corporation more than 50% of the voting power or value of the stock of which is owned by U.S. shareholders on any day during the foreign corporation's taxable year. See Sec. 957(a).
2 A U.S. shareholder is a U.S. person who owns at least 10% of the total combined voting power of all classes of the foreign corporation's stock entitled to vote. See Sec. 951(b).
3 An obligation of a related person is an investment in which triggers a deemed dividend to the CFC's U.S. shareholders.
4 See Jacobs Engineering Group, Inc. v. United States, 79 AFTR, 2d 97-1673.
Reader Comments» Post a comment