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A Controlled Foreign Corporation [4] is any corporation organized outside the U.S. (a foreign corporation) that is more than 50% owned by U.S. Shareholders. A U.S. Shareholder is any U.S. person (individual or entity) that owns 10% or more of the foreign corporation. Complex rules apply to attribute ownership of one person to another person.
Thus the corporation is a domestic corporation in Delaware or Nevada, and is a foreign corporation in any other state (or country) with which it registers. While there may be tax benefits as a result of choosing where a corporation's domestic jurisdiction is located, registering as a foreign corporation in another state can create new tax ...
Foreign personal holding company income (FPHCI) is defined for U.S. controlled foreign corporation rules [1] and, with modifications, for U.S. foreign tax credit rules. [2] It consists of interest, dividends, rents, royalties, gains on property producing FPHCI, and certain other items. Exceptions are provided for active rents and royalties ...
In the United States, rules provides that U.S. shareholders of a Controlled Foreign Corporation (CFC) must include their shares of income or investment of E&P by the CFC in U.S. property. [213] U.S. shareholders are U.S. persons owning 10% or more (after the application of complex attribution of ownership rules) of a foreign corporation.
This is an accepted version of this page This is the latest accepted revision, reviewed on 18 December 2024. Legal entity incorporated through a legislative or registration process For other uses, see Corporation (disambiguation). "Corporate" redirects here. For other uses, see Corporate (disambiguation). "Corp." redirects here. Not to be confused with "Copr.". This article is part of a series ...
A foreign eligible entity that became an association taxable as a corporation under the foreign default rule described below. A foreign corporation that is not identified as a corporation under Treasury regulations §301.7701-2(b)(8). If a foreign corporation is not identified on the list included in these regulations, it qualifies as an ...
A man is facing multiple charges after Mississippi police say they found him asleep in a car at a highway intersection with marijuana, a gun and a bottle of alcohol.
Foreign ownership of assets is widespread in a modern, globally integrated economy, at both the corporate and individual levels. An example of the former is when a corporation acquires part, or all, of another company headquartered overseas, or when it purchases property, infrastructure, access rights or other assets in countries abroad. [2]