This is an important question. A corporation is a controlled foreign corporation if more than 50% of its shares are owned by U.S. shareholders. However, the definition of a U.S. shareholder for purposes of the CFC rules is qualified: only those U.S. citizens (or resident aliens) who own ten-percent (10%) or more of the shares of the corporation count.
What is a Controlled Foreign Corporation (CFC)? was last modified: March 24th, 2018 by David Klasing