Controlled Foreign Corporation - CFC


Controlled Foreign Corporation - CFC
A corporate entity that is registered and conducts business in a different jurisdiction or country than the residency of the controlling owners. Control of the foreign company is defined, in the U.S., according to the percentage of shares owned by U.S. citizens.

Controlled foreign corporation (CFC) laws work alongside tax treaties to dictate how taxpayers declare their foreign earnings. A CFC is advantageous for companies when the cost of setting up a business, foreign branches or partnerships in a foreign country is lower even after the tax implications, or when the global exposure could help the business grow.

The CFC structure was created to help prevent tax evasion, which was done by setting up offshore companies in jurisdictions with little or no tax. Each country has its own CFC laws, but most are similar in that they tend to target individuals over multinational corporations when it comes to how they are taxed. For this reason, having a company qualify as independent will exempt it from CFC regulations.

Countries differ in how they define the independence of a company. The determination can be based on how many individuals have a controlling interest in the company, as well as the percentage they control. For example, minimums can range from fewer than 10 to over 100 people, or 50% of voting shares, or 10% of the total outstanding shares.


Investment dictionary. . 2012.

Look at other dictionaries:

  • controlled foreign corporation — Any foreign corporation in which more than 50 percent of the total combined voting power of all classes of stock entitled to vote or the total value of the stock of the corporation is owned by U.S. shareholders on any day during the taxable year… …   Black's law dictionary

  • controlled foreign corporation — Any foreign corporation in which more than 50 percent of the total combined voting power of all classes of stock entitled to vote or the total value of the stock of the corporation is owned by U.S. shareholders on any day during the taxable year… …   Black's law dictionary

  • foreign corporation — Domestic and foreign corporations. With reference to the laws and the courts of any given state, a domestic corporation is one created by, or organized under, the laws of that state; a foreign corporation is one created by or under the laws of… …   Black's law dictionary

  • foreign corporation — Domestic and foreign corporations. With reference to the laws and the courts of any given state, a domestic corporation is one created by, or organized under, the laws of that state; a foreign corporation is one created by or under the laws of… …   Black's law dictionary

  • Corporation — This article is about business corporations. For other uses, see Corporation (disambiguation). Corporate redirects here. For the Bollywood film, see Corporate (film). A corporation is created under the laws of a state as a separate legal entity… …   Wikipedia

  • corporation — An artificial person or legal entity created by or under the authority of the laws of a state. An association of persons created by statute as a legal entity. The law treats the corporation itself as a person which can sue and be sued. The… …   Black's law dictionary

  • corporation — An artificial person or legal entity created by or under the authority of the laws of a state. An association of persons created by statute as a legal entity. The law treats the corporation itself as a person which can sue and be sued. The… …   Black's law dictionary

  • corporation — A legal entity that is separate and distinct from its owners. A corporation is allowed to own assets, incur liabilities ( liability), and sell securities, among other things. Bloomberg Financial Dictionary An entity created by or under the… …   Financial and business terms

  • Foreign Direct Investment - FDI — An investment abroad, usually where the company being invested in is controlled by the foreign corporation. An example of FDI is an American company taking a majority stake in a company in China …   Investment dictionary

  • Foreign ownership of companies of Canada — has long been a controversial political issue in Canada. Concerns regarding foreign ownership generally regard ownership by individuals or companies based in the United States, though foreign ownership occurs from entities and individuals based… …   Wikipedia

  • Foreign internal defense — (FID) is used by a number of Western militaries, explicitly by the United States but sharing ideas with countries including France and the United Kingdom, to describe an approach to combating actual or threatened insurgency in a foreign state… …   Wikipedia


Share the article and excerpts

Direct link
Do a right-click on the link above
and select “Copy Link”

We are using cookies for the best presentation of our site. Continuing to use this site, you agree with this.