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A "US Shareholder" for Purposes of CFC Classification Is Any U

question 137

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A "U.S. shareholder" for purposes of CFC classification is any U.S. person who owns directly, indirectly, or constructively at least 10% of the voting power or value of a foreign corporation.


Definitions:

Appointed Head

A leader or executive placed in their position by a higher authority rather than through election or self-assertion.

Mentor Or Sponsor

A relationship in which an experienced individual (mentor or sponsor) provides guidance, advice, and support to a less experienced person to help them progress in their career or personal development.

Developmental Groups

Groups focused on the growth and development of their members, often through shared learning experiences, skill-building activities, or supportive interactions.

Psychological Groups

Collections of individuals who share emotional connections, common purposes, or identify as members of the same group.

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