Form 5471에서 CFC의 정의는 무엇인가요?

In the context of IRS Form 5471, a Controlled Foreign Corporation (CFC) is defined as a foreign corporation where U.S. shareholders collectively own more than 50% of the total combined voting power of all classes of stock entitled to vote, or more than 50% of the total value of all classes of stock. This ownership is determined by considering direct, indirect, and constructive ownership rules.

For a U.S. person to be considered a shareholder of a CFC, they must own at least 10% of the total combined voting power or value of the foreign corporation's stock. If a foreign corporation meets the CFC definition, U.S. shareholders who own 10% or more of the stock may be subject to reporting and taxation on certain types of income earned by the CFC, such as Subpart F income or GILTI (Global Intangible Low-Taxed Income), even if that income has not been distributed.