A "U.S. shareholder" for purposes of CFC classification is any U.S. person who owns directly, indirectly, and constructively at least 50% of the voting power of a foreign corporation.

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A "U.S. shareholder" for purposes of CFC (Controlled Foreign Corporation) classification is defined as a U.S. person who owns directly, indirectly, or constructively at least 10% of the total combined voting power of all classes of stock of a foreign corporation.

A "US Shareholder" for Purposes of CFC Classification Is Any U