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What is a Controlled Foreign Corporation?
Section 957 of the Internal Revenue Code defines a foreign corporation as being “controlled” if more than 50 percent of the total combined voting power of all classes of stock of such corporation entitled to vote, or more than 50 percent of the value of all its outstanding stock, is owned (directly, indirectly, or constructively) by U.S. shareholders on any day during the foreign corporation’s tax year. A shareholder for purposes of determining control is defined as a “ person” owning 10 percent or more of the foreign corporation’s voting stock. For purposes of these statistics, a foreign corporation was “controlled” only if a single corporation satisfied the ownership requirements for an uninterrupted period of at least 30 days. These are the only foreign corporations for which complete Form 5471 filings are required. U.S corporations may also control a CFC through a partnership where the corporation is the controlling partner. To the extent possible, these CFCs have also been included in these statistics.
Please visit Controlled Foreign Corporations Statistics for data tables and articles from this study.
For Metadata by year of study.