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Kipp, a U.S. shareholder under the CFC provisions, owns 40% of a CFC. If the CFC's Subpart F income for the taxable year is $200,000, Kipp is taxed on receipt of a constructive dividend of $80,000.
Tort
A violation of another person’s rights or a civil wrongdoing that does not arise out of a contract or statute; primary types are intentional, negligent, and strict-liability torts.
Agent Liability
Refers to the legal responsibility of an agent to their principal, including obligations and potential for repercussions if the agent acts outside their authority or against the interests of the principal.
Principal
In law, the person who authorizes an agent to act on their behalf; in finance, the original amount of money invested or loaned.
Vicarious Liability
The liability or responsibility imposed on a person, a party, or an organization for damages caused by another; most commonly used in relation to employment, with the employer held vicariously liable for damages caused by its employees.
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