Controlled Foreign Corporation

About Controlled Foreign Corporation:

Controlled Foreign Corporation (CFC) is a foreign corporation more than 50% of whose value or interest is owned by U.S. shareholders. A U.S. shareholder is a U.S. citizen who owns 10% or more of the voting stock. The 10% shareholders of a CFC are required to include in income currently their pro rata share of the subpart F income of the CFC. Subpart F income generally includes passive activity income and certain types of active income considered to be particularly mobile (but not active business income). Former IRC (check if this IRC provision is current here) §§951-964.