Aliant, LLP

Description

However, it is important to note that subpart F does not purport to tax or directly affect the foreign corporation. Rather, the tax is assessed against the "U.S. shareholder" of the foreign corporation. Even then, not all U.S. taxpayers who own shares in the closely-held foreign corporation are subject to tax on the corporation's income. Only those shareholders who own, directly or indirectly, 10 percent or more of the corporation's voting power are considered U.S. shareholders and are therefore subject to tax on the foreign corporation's income.

Companies nearby