Paper, Inc., a corporation organized in Germany, has the following owners, all owner voting shares:

15% owned by Ben, a US individual

10% owned by Sarah, a US individual

75% Fork, LLP, a foreign partnership

oFork has the following partners

15% owned by Abigail, a US individual

15% owned by Helen, a US individual

15% owned by Lauren, a US individual

10% owned by Abe, a US individual

10% owned by Adele, a US individual

15% owned by Mark, a foreign individual

15% owned by Nate, a foreign individual

5% owned by Lynn, a foreign individual

Is Paper Inc. a CFC? Who are the US shareholders?

Can you please talk about the Direct ownership, indirect ownership, constructive ownership - who applies here?

A similar Example: to this problem: U.S. Corporation DC owns 20% of Foreign Corporation FC1, which in

turn owns 50% of Foreign Corporation FC2.DC is deemed to own 10% of FC2

(20% of 50%).