What is Controlled foreign corporation (CFC)?
In short
A controlled foreign corporation (CFC) is a foreign corporation more than 50% owned, by vote or value, by US shareholders, each of whom owns at least 10%.
Key takeaways
- US shareholders may have to include certain income of a CFC currently, before it is distributed, under the anti-deferral rules.
- The former global intangible low-taxed income regime was renamed net CFC tested income from 2026.
- Ownership through family members and related entities counts toward the tests.
Where it's tested
TCP: Multi-Jurisdictional & International Basics — study notes, a five-minute revision sheet and practice questions.
Practise: 3 questions
Question 1 of 3 · 0 answered
A foreign corporation is a controlled foreign corporation when: