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International Practice Unit: What the I.R.S. Looks for When Deciding if a U.S. Shareholder Has an Interest in a C.F.C.

Volume 3 No 1   /   Read Article  

By Rusudan Shervashidze and Stanley C. Ruchelman

Rusudan Shervashidze and Stanley C. Ruchelman explain the tests the I.R.S. applies to determine whether a foreign corporation is a C.F.C. and a U.S. person is a “U.S. Shareholder” potentially subject to tax under Subpart F. They explain the tax forms that examiners are encouraged to look for and the telltale signs of direct, indirect, and constructive ownership of shares by U.S. persons. See more →

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