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The following persons own Curtis Corporation, a foreign corporation: Clarence, U.S. individual 35% John, U.S. individual 15% Henry, U.S. individual 8% James, U.S. individual 12%
The following persons own Curtis Corporation, a foreign corporation:
Clarence, U.S. individual | 35% |
John, U.S. individual | 15% |
Henry, U.S. individual | 8% |
James, U.S. individual | 12% |
Carl, non-U.S. individual | 30% |
None of the shareholders are related to each other. Subpart F Income for the tax year is $400,000. No distributions are made. Which of the following statements is correct?
John is not a United States shareholder for purposes of determining whether Curtis Corporation is a Controlled Foreign Corporation (CFC). | ||
Carl is not a United States shareholder for purposes of determining whether Curtis Corporation is a Controlled Foreign Corporation (CFC). | ||
Henry is a United States shareholder for purposes of determining whether Curtis Corporation is a Controlled Foreign Corporation (CFC). | ||
Curtis Corporation is not a Controlled Foreign Corporation (CFC). |
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