Controlled Foreign Corporations | Midpage

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United States Code

Subpart F

Controlled Foreign Corporations

951Amounts included in gross income of United States shareholders 951ANet CFC tested income included in gross income of United States shareholders 951BAmounts included in gross income of foreign controlled United States shareholders 952Subpart F income defined 953Insurance income 954Foreign base company income 956Investment of earnings in United States property 957Controlled foreign corporations; United States persons 958Rules for determining stock ownership 959Exclusion from gross income of previously taxed earnings and profits 960Deemed paid credit for subpart F inclusions 961Adjustments to basis of stock in controlled foreign corporations and of other property 962Election by individuals to be subject to tax at corporate rates 964Miscellaneous provisions 965Treatment of deferred foreign income upon transition to participation exemption system of taxation