Congress introduced the controlled foreign corporation (CFC) rules in 1962 to prevent U.S. taxpayers from deferring federal income taxes on income earned in closely held foreign companies, namely by forcing U.S. shareholders with requisite levels of ownership to recognize certain types of income earned by CFCs without regard to whether such earnings were actually distributed. Like many other anti-deferral regimes, the CFC regime includes ownership attribution rules pursuant to which stock
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