Which of the following persons should not be treated as a "U.S. shareholder" of a controlled foreign corporation (CFC) for subpart F purposes?

Question

Quizplus · Accepted Answer

For subpart F purposes, a U.S. shareholder is defined as a U.S. person who owns 10% or more of the total combined voting power of all classes of stock of a CFC. Therefore, option A and B, both owning 15% of the CFC, would be considered U.S. shareholders. However, option C, owning only 5% of the CFC, would not be considered a U.S. shareholder for subpart F purposes.

Which of the Following Persons Should Not Be Treated as a "U.S