Identify whether the corporations described below are controlled foreign corporations. a. Shetland PLC, a UK corporation, has

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Identify whether the corporations described below are controlled foreign corporations.

a. Shetland PLC, a UK corporation, has two classes of stock outstanding, 75 shares of class AA stock and 25 shares of class A stock. Each class of stock has equal voting power. Angus owns 35 shares of class AA stock and 20 shares of Class A stock. Angus is a U.S. citizen who resides in England.

b. Tony and Gina, both U.S. citizens, own 5% and 10%, respectively, of the voting stock of DaVinci S.A., an Italian corporation. Tony and Gina are also equal partners in Roma Corporation, an Italian corporation that owns 50% of the DaVinci stock.

c. Pierre, a U.S. citizen, owns 45 of the 100 shares outstanding in Vino S.A., a French corporation. Pierre's father, Pepe, owns 8 shares in Vino. Pepe also is a U.S. citizen. The remaining 47 shares are owned by non-U.S. individuals.

Corporation
A Corporation is a legal form of business that is separate from its owner. In other words, a corporation is a business or organization formed by a group of people, and its right and liabilities separate from those of the individuals involved. It may...
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Taxation Of Individuals And Business Entities 2015

ISBN: 9780077862367

6th Edition

Authors: Brian Spilker, Benjamin Ayers, John Robinson, Edmund Outslay, Ronald Worsham, John Barrick, Connie Weaver

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