U.S. Tax Treatment of CFCs
Understanding how controlled foreign corporation rules can affect U.S. shareholders’ current tax inclusions.
Format
Online
NASBA Field of Study
Taxes
Level
Intermediate
CPE Credits
2
Author(s)
AICPA staff
Availability
1 year
Product Number
USITCFC26SSO
CFC rules in practice
U.S. shareholders of foreign corporations must understand when a foreign corporation becomes a controlled foreign corporation (CFC) and how that status can trigger current U.S. tax consequences. This course covers the ownership thresholds, attribution rules, and income inclusion concepts that drive CFC analysis under the IRC.
Ownership rules applied
In this course, learners examine how direct, indirect, and constructive ownership rules are used to determine the percentage of stock owned by a U.S. shareholder as well as how constructive ownership rules can be modified by:
- Family attribution
- Partnership and estate attribution
- Corporate attribution
- Options to acquire stock
Income tax consequences and Section 962
Learners review how U.S. shareholders may be subject to current taxation on Subpart F income and NCTI, why direct and indirect ownership under Section 958(a) matters when measuring inclusions, and how a Section 962 election can affect eligible individuals, trusts, and estates.
Note: This program includes content from the U.S. International Tax Certificate.
Who Will Benefit
- Tax professionals advising U.S. shareholders with foreign corporation ownership
- CPAs and accounting professionals working on international tax compliance
- Corporate tax professionals responsible for CFC, Subpart F, or NCTI analysis
- Professionals seeking a practical review of CFC ownership and attribution rules
Key Topics
- Controlled foreign corporations
- U.S. shareholders
- Direct and indirect ownership
- Constructive ownership
- Subpart F income
- NCTI
- Section 962 elections
- Section 958(b)(4) and Section 951B
Learning Outcomes
- Identify when an entity meets controlled foreign corporation criteria.
- Recognize shareholder ownership rules.
- Distinguish entity classification from income consequences.
Group ordering for your team
2 to 5 registrants
Save time with our group order form. We’ll send a consolidated invoice to keep your learning expenses organized.
Start order6+ registrants
We can help with group discounts. Email client.support@aicpa-cima.com
US customers call 1-800-634-6780 (option 1)
The Association is dedicated to removing barriers to the accountancy profession and ensuring that all accountancy professionals and other members of the public with an interest in the profession or joining the profession, including those with disabilities, have access to the profession and the Association's website, educational materials, products, and services.The Association is committed to making professional learning accessible to all product users. This commitment is maintained in accordance with applicable law. For additional information, please refer to the Association's Website Accessibility Policy. As part of this commitment, this product is closed-captioned. For additional accommodation requests please contact adaaccessibility@aicpa-cima.com and indicate the product that you are interested in (title, etc.) and the requested accommodation(s): Audio/Visual/Other. A member of our team will be in contact with you promptly to make sure we meet your needs appropriately.