controlled foreign corporation


controlled foreign corporation
Controlled Foreign Corporation (CFC)
USA
A foreign corporation in which more than 50% of the total combined voting power of its stock or the total value of its stock is owned by "United States Shareholders" (defined as a United States person (IRC § 957(c)) who owns 10% or more of the total combined voting power of foreign corporation's stock (IRC §§ 951(b) and 957(a)).
A United States person generally means a citizen or resident of the US, a domestic partnership, a domestic corporation, an estate whose income is subject to US federal income tax regardless of its source or a trust if the US can exercise primary supervision over the trust's administration and one or more United States persons are authorized to control all substantial decisions of the trust.

Practical Law Dictionary. Glossary of UK, US and international legal terms. . 2010.

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