U.S. Income Tax Compliance
U.S. Income Tax Compliance
U.S. Income Tax Compliance
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Form 5471<br />
• A U.S. person has control of a foreign<br />
corporation if, at any time during the year, it<br />
owns stock possessing more than 50% of the<br />
total combined voting power of all classes of<br />
stock of the foreign corporation entitled to vote<br />
or more than 50% of the total value of shares of<br />
all classes of stock of the foreign corporation<br />
• A controlled foreign corporation is a foreign<br />
corporation that is more than 50% owned by<br />
U.S. shareholders (U.S. persons that own at<br />
least 10% of the total combined voting power of<br />
all classes of stock entitled to vote
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