Controlled Foreign Corporation
http://www.irs.gov/uac/SOI-Tax-Stats-Controlled-Foreign-Corporations-Metadata (U.S.)
Type
Entity
Jurisdiction
Global
Sponsor/Regulator
Various: In the U.S., Internal Revenue Service
Description
A corporate entity that is registered and conducts business in a different jurisdiction or country than the residency of the controlling owners. In the U.S, control of the foreign company is based on the percentage of shares owned by U.S. citizens, typically over 50%.
Key Facts
CFC rules are features of an income tax system designed to limit artificial deferral of tax by using offshore low-taxed entities.
Who it affects
Countries with CFC rules include, but are not limited to, the United States (since 1962), the United Kingdom, Germany, and Japan.
Additional Information
Controlled Foreign Company Regimes Essentials 2012 (Deloitte)
CFC on Wikipedia