54. Identify whether the corporations described below are controlled foreign corporations.

a. Shetland PLC, a U.K. corporation, has two classes of stock outstanding, 75 shares of class AA stock and 25 shares of class A stock. Each class of stock has equal voting power and value. Angus owns 35 shares of class AA stock and 20 shares of class A stock. Angus is a U.S. citizen who resides in England.

b. Tony and Gina, both U.S. citizens, own 5 percent and 10 percent, respectively, of the voting stock and value of DaVinci S.A., an Italian corporation. Tony and Gina are also equal partners in Roma Corporation, an Italian corporation that owns 50 percent of the DaVinci stock.

c. Pierre, a U.S. citizen, owns 45 of the 100 shares outstanding in Vino S.A., a French corporation. Pierre’s father, Pepe, owns 8 shares in Vino. Pepe also is a U.S. citizen.

The remaining 47 shares are owned by non-

U.S. individuals.