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Abe,a USShareholder Under the CFC Provisions,owns 49% of a CFC

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Abe,a U.S.shareholder under the CFC provisions,owns 49% of a CFC.If the CFC's Subpart F income for the taxable year is $200,000,Abe is not taxed on receipt of a constructive dividend of $98,000 because he doesn't own more than 50% of the CFC.


Definitions:

Garnishment

Garnishment is a legal process by which a creditor obtains a court order to redirect a portion of an individual's earnings or assets directly from third parties, like employers or banks, to satisfy a debt.

Post-Judgment Remedy

Legal means available to a creditor to collect what is owed following a court judgment.

Bankruptcy Code

The set of laws that govern bankruptcy proceedings, providing protection to indebted individuals and entities seeking to rearrange or eliminate their debts.

Commencement

Commencement refers to the beginning or start of something, often used in legal contexts to denote the start of legal proceedings or the operative period of a contract.

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