A Japanese corporation owned by eleven U.S. individuals cannot be treated as a controlled foreign corporation for U.S. tax purposes.

Name: A Japanese corporation owned by eleven U.S. individuals cannot be treated as a controlled foreign corporation for U.S. tax purposes.
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Question

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For a corporation to be a CFC, it must be owned more than 50 percent by U.S. persons owning at least 10 percent of the corporation. One of the individuals could own more than 50 percent of the stock, making the corporation a CFC.

A Japanese Corporation Owned by Eleven U