A Foreign Corporation with a Single Class of Stock Is

question 78

Essay

A foreign corporation with a single class of stock is owned 8% by Bert, 49% by Xi Yong, 30% by Ernie, and 13% by Mark. Bert, Ernie, and Mark are U.S. citizens, and Xi Yong is a nonresident alien. Bert is Ernie's son. Is the foreign corporation a controlled foreign corporation (CFC)?

---

Definitions:

Retake Possession

The act of reclaiming ownership or control of property, typically by a seller or lender from whom the property was bought on credit or leased.

Pay Installments

To make payments for a good or service over a period of time in portions, rather than paying the full amount upfront.

Severance

An owner’s removal of chattel that he has affixed; separation or division of joint ownership; action by one of the co-owners that is inconsistent with joint tenancy.

Joint Ownership

Shared ownership of property by two or more parties where all owners have equal rights and obligations regarding the property.