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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:

Ingratiation

A psychological technique involving efforts to make oneself more likable to others through flattery or the creation of goodwill.

Expert Power

Influence and authority derived from possessing extensive knowledge or expertise in a particular area.

Referent Power

Influence based on being admired or respected, allowing individuals to persuade others because of their personality, integrity, or other attractive traits.

Coercive Power

The ability to influence others' behavior by threats, punishment, or negative reinforcement.

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