CFC

(redirected from Controlled Foreign Corporation)
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CFC

(organic chemistry)
References in periodicals archive ?
The SOI Corporate sample is the basis for the SOI Controlled Foreign Corporation sample.
The regulations will not apply if neither the parent nor the subsidiary corporation is a controlled foreign corporation immediately before or after the triangular reorganization.
954-3(b)(2)(ii), a branch or similar establishment of a controlled foreign corporation treated as a separate corporation purchasing or selling on behalf of the remainder of the controlled foreign corporation under paragraph (b)(2) (ii)(b) of this section, or the remainder of the controlled foreign corporation treated as a separate corporation purchasing or selling on behalf of a branch or similar establishment of the controlled foreign corporation under [section]1.
Specifically, it is a controlled foreign corporation if more than 25 percent, rather than 50 percent, of the voting power or value of shares is owned by U.
In addition, after 1986, deficits in earnings and profits of a controlled foreign corporation are related to specific shareholders.
Attribution rules were introduced in the 1962 Act to account for various ownership structures that would otherwise avoid the requirements for declaring a foreign corporation a controlled foreign corporation.
Code contains an exception foreign the PFIC regime for a United States shareholder of a controlled foreign corporation that is similar to the CFA exception in the FIE Rules.
It says the distributing parent company must include in income (as a dividend) the amount by which the value of the distributed stock exceeds its basis (in the parent's hands) but only to the extent of the earnings and profits accumulated in years when the distributed entity was a controlled foreign corporation.
965, which creates a temporary incentive that allows them to repatriate accumulated foreign earnings via a dividends-received deduction for certain controlled foreign corporation (CFC) dividends.
A federal controlled foreign corporation (CFC) is generally defined as an entity that is organized in a foreign country and is owned greater than 50 percent by U.
shareholder of a controlled foreign corporation (CFC) is deemed a participant in a reportable transaction where the CFC engages in a transaction that, were the CFC a domestic U.

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