Which of the following persons should not be treated as a "U.S. shareholder" of a controlled foreign corporation (CFC) for subpart F purposes?
A) A U.S. citizen owning 5 percent of the CFC.
B) A U.S. citizen owning 15 percent of the CFC.
C) A U.S. corporation owning 15 percent of the CFC.
D) All of the above named persons are U.S. shareholders for subpart F purposes.

Question

Quizplus · Accepted Answer

To be a U.S. shareholder, a U.S. person must own at least 10 percent of the stock of a CFC.

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