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A Foreign Corporation with a Single Class of Stock Is

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Essay

A foreign corporation with a single class of stock is owned equally by Jericho Corporation, a U.S. corporation, and Joshua, a nonresident alien. Joshua owns no Alpha Corporation stock. Is the foreign corporation a controlled foreign corporation (CFC)?

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Definitions:

Quarterly Compounding

A technique in which interest is computed and then compounded to the main amount quarterly.

Nominal Rate

The stated interest rate of a bond or loan, not adjusting for inflation or the compounding of interest.

Monthly Compounding

The monthly interest computation strategy that involves both the starting principal amount and the earned interest from earlier times.

Appraised Value

Represents the estimated monetary value of a property as determined by a qualified appraiser based on its characteristics and the selling prices of comparable properties.

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