Controlled Foreign Corporations | Practical Law
This Practice Note provides an overview of the US federal income tax rules that apply to controlled foreign corporations (CFCs) and their US shareholders. Specifically, this Note discusses the definition of a CFC, the types of income that are classified as Subpart F income, the tax issues relating to a CFC's investment in US property, the new global intangible low-taxed income tax and participation exemption, and the US tax consequences for US investors in a CFC.