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 these persons are U.S. shareholders for subpart F purposes
Correct Answer:
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