WebSection 957 (a) defined the term “CFC” as any foreign corporation of which more than 50 percent of the total combined voting power of of all classes of stock entitled to vote was owned, directly, indirectly, or constructively … WebHierarchy JSON - Title 26; Content HTML - Section 1.958-1; Content XML - Section 1.958-1; Information and documentation can be found in our developer resources. ... Accordingly, PRS is a United States shareholder under section 951(b), and FC is a controlled foreign corporation under section 957(a). Individual A is also a United States ...
26 U.S. Code § 957 - Controlled foreign corporations; …
WebI.R.C. § 957 (a) General Rule —. For purposes of this title, the term “controlled foreign corporation” means any foreign corporation if more than 50 percent of—. I.R.C. § 957 (a) … WebJan 1, 2024 · --For purposes of sections 951(b), 954(d) (3), 956(c)(2), and 957, section 318(a) (relating to constructive ownership of stock) shall apply to the extent that the effect is to treat any United States person as a United States shareholder within the meaning of section 951(b), to treat a person as a related person within the meaning of section ... something equivalent to butter rugs
Guidance on Passive Foreign Investment Companies
WebJan 15, 2024 · 26 CFR 1 Agency/Docket Number: TD 9936 RIN: 1545-BO59 Document Number: 2024-27009. Document Details. ... Section 957(a) provides that, for purposes of the Code, a CFC means any foreign corporation more than 50 percent owned (by vote or value, taking into account section 958(b) constructive ownership rules) by U.S. shareholders on … WebFor purposes of this title, the term “United States shareholder” means, with respect to any foreign corporation, a United States person (as defined in section 957(c)) who owns (within the meaning of section 958(a)), or is considered as owning by applying the rules of ownership of section 958(b), 10 percent or more of the total combined voting power of all … Web(a) General rule For purposes of this title, the term “ controlled foreign corporation ” means any foreign corporation if more than 50 percent of— (1) the total combined voting power of all classes of stock of such corporation entitled to vote, or (2) the total value of the stock … “The amendments made by this section [enacting this section and amending … something error: 497 send http to https port