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A Foreign Corporation with a Single Class of Stock Is

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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. The shareholders are not related. Is the foreign corporation a controlled foreign corporation (CFC)?


Definitions:

Bureaucratic Administration

A system of management and administration characterized by hierarchical structure, fixed rules, and a clear division of labor.

Lifetime Allegiance

This concept refers to a long-term loyalty or commitment by an individual to an organization, cause, or entity, often spanning the entire duration of one's career or life.

Adaptive Perspective

An approach or mindset that emphasizes flexibility and the ability to adjust to new conditions or environments.

John Holland's Theory

A theory of career and vocational choice based upon personality types, suggesting that people are more satisfied in environments matching their personal inclinations.

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