The earnings of foreign corporations generally are not taxed in the U.S. until the foreign corporation repatriates its earnings through the distribution of dividends. This is known as the concept of “deferral” (i.e., U.S. taxation is deferred until repatriation). Various exceptions to deferral exist today (often referred to as “anti-deferral” regimes). Subpart F income is one of these exceptions to deferral. Subpart F income only applies to Controlled Foreign Corporations (CFC’s).
A CFC, very generally, is defined as a foreign corporation in which U.S. persons own more than 50 percent of the corporation’s stock (measured by vote or value). Stock ownership includes direct ownership as well as stock owned indirectly or constructively.
When a CFC earns subpart F income, the United States generally taxes the corporation’s U.S. shareholders curre
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