A foreign corporation is owned by five unrelated individuals. John, Sam, and David are U.S. citizens who own 30%, 18% and 9%, respectively, of the foreign corporation's single class of stock. Alberto and Manuel are nonresident aliens who own 37% and 6%, respectively, of the foreign corporation's stock. Which of the following statements is true?
A) There are three "U.S. shareholders" and the foreign corporation is a controlled foreign corporation (CFC) .
B) There are three "U.S. shareholders" and the foreign corporation is not a controlled foreign corporation (CFC) .
C) There are two "U.S. shareholders" and the foreign corporation is not a controlled foreign corporation (CFC) .
D) There are two "U.S. shareholders" and the foreign corporation is a controlled foreign corporation (CFC) .
Correct Answer:
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