CFC

(redirected from Controlled Foreign Corporation)
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CFC

(organic chemistry)
References in periodicals archive ?
The FDE data in this article pertain only to active FDEs that are owned by controlled foreign corporations.
Department of Treasury and the Internal Revenue Service issued final, temporary and proposed regulations to provide guidance regarding 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 (hereinafter the "December 2008 regulations").
shareholder" and the lower 25 percent threshold of controlled foreign corporation status.
7) Form 5471 significantly increased the amount of information required to be reported for each controlled foreign corporation, although not all fliers were required to complete all schedules.
In addition, subsection 1297(e) of the Code contains an exception from the PFIC regime for a United States shareholder of a controlled foreign corporation that is similar to the controlled foreign affiliate exception in the FIE Rules.
6011-4T(c)(3)(ii)(B), a reporting shareholder is a "United States shareholder" in a foreign personal holding company or a controlled foreign corporation (as defined in section 551(a) or 951(b), respectively) or is a 10-percent shareholder in a passive foreign investment that is a qualified electing fund (as specified in sections 1293 and 1295).
The Omnibus Budget Reconciliation Act of 1993 adds an additional layer of complexity to the current tax on controlled foreign corporation (CFC) earnings.
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.
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.
parent that are part of a back-to-back loan arrangement with a controlled foreign corporation (CFC).

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