Question
Definition of a CFC. In each of the following scenarios, determine whether a foreign corporation with a single class of stock outstanding, is a controlled
Definition of a CFC. In each of the following scenarios, determine whether a foreign corporation with a single class of stock outstanding, is a controlled foreign corporation.
a. The foreign corporation's stock is owned equally by Alpha, a U.S. corporation, and Bart, a U.S. citizen, who owns no Alpha stock.
b. Assume the same facts as in Part a except Bart is a nonresident alien.
c. The foreign corporation's stock is owned 7% by Art, 49% by Phong, 29% by Colleen, and 15% by Danielle. Art, Colleen, and Danielle are US, citizens, and Phong is a nonresident alien. All four individuals are unrelated.
d. Assume the same facts as in Part c except Danielle is Art's daughter.
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