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OpenJurist

CFC group

Defined in 1 place of the United States Code.

For purposes of paragraph (1), the term “CFC group” means 1 or more chains of controlled foreign corporations connected through stock ownership with a top tier corporation which is a controlled foreign corporation, but only if—

(A) the top tier corporation owns directly more than 50 percent (by vote or value) of the stock of at least 1 of the other controlled foreign corporations, and

(B) more than 50 percent (by vote or value) of the stock of each of the controlled foreign corporations (other than the top tier corporation) is owned (directly or indirectly) by one or more other members of the group.

If any foreign corporation ceases to be a controlled foreign corporation during any taxable year—

Source

  • 1994–present26 U.S.C. § 956AInternal Revenue Code · Repealed. Pub. L. 104188, title I, 1501(a)(2), Aug. 20, 1996, 110 Stat. 1825] · for purposes of this section