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Bob is a U . S . person and Boris is a foreign person. Each owns 5 0 % of the stock in ForCo. Bob

Bob is a U.S. person and Boris is a foreign person. Each owns 50% of the stock in ForCo. Bob can appoint three members of ForCo's board of directors, and Boris can appoint two members of ForCo's board of directors. Is ForCo a CFC? Why or why not?
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