The statistics presented below pertain only to FDEs with tax owners that are controlled foreign corporations
Income derived by the branch or similar establishment, or by the remainder of the controlled foreign corporation
, shall not be considered foreign base company sales income if the income would not be so considered if it were derived by a separate controlled foreign corporation
under like circumstances.
Without a shareholder, the captive was not a controlled foreign corporation
The 1962 legislation also increased the Form 2952 filing requirement by extending the definition of a controlled foreign corporation
to include any foreign corporation within a chain of control.
Controlled foreign corporations
(CFCs), as defined in section 957 of the Internal Revenue Code, that have Subpart F income.
11) These special rules, including the controlled foreign corporation
netting rule, are outlined in Regs.
Revising the definition of confidential transactions to eliminate transactions entered into by controlled foreign corporations
(CFCs) for the purpose of reducing foreign or state and local taxes.
However, certain look-through rules for foreign tax credit basket purposes that would generally apply to dividends from a controlled foreign corporation
(CFC) will not apply to dividends on earnings accumulated before the corporation became a CFC.
controlled foreign corporation
and passive foreign investment company rules.
For controlled foreign corporation
(CFC) captives, all insurance income that is not same-country insurance income (SCII) is deemed to be subpart F income subject to current inclusion.
55) Subsection 1297(f) of the Code provides that asset values are generally determined by value, except that assets of a non-publicly traded corporation that is a controlled foreign corporation
or that makes an election may be determined by their adjusted bases.
1248 applies to shareholders with a 10%-or-more voting power in a controlled foreign corporation
6011-4T(c)(3)(ii) requires certain United States shareholders in controlled foreign corporations
to report their "indirect" participation if the controlled foreign corporation
directly participates in a reportable transaction described in Temp.
Such a foreign corporation is equivalent to a controlled foreign corporation
TEI recommended eliminating individual filings for each controlled foreign corporation
(CFC) and substituting a schedule of CFCs containing key information, including the balance in the earnings and profits (E&P) and tax pools.