United States shareholder definition
Examples of United States shareholder in a sentence
Subpart F income is included in the gross income of a United States shareholder of a con- trolled foreign corporation under the rules of section 951 and the regulations thereunder, and thus is subject to cur- rent taxation under section 1 or 11 of the Code.
The aggregate amount of related controlled foreign corporation obligations held by the related United States shareholder in each limitation category equals the sum of the value of all such obligations in each limitation category.
If a significant holder is a controlled foreign corporation (within the meaning of section 957), each United States shareholder (within the meaning of section 951(b)) with respect thereto must include this statement on or with its return.
For pur- poses of this section, a United States shareholder is a person described in sec- tion 951(b) or section 953(c).
In the case of a controlled foreign cor- poration that is a look-through entity, the tax attributes to be taken into ac- count are those of any person that is a United States shareholder (as defined in paragraph (b)(2)(iii)(d)(5) of this sec- tion) of the controlled foreign corpora- tion, or, if the United States share- holder is a look-through entity, a United States person that owns an in- terest in such shareholder directly or indirectly through one or more look- through entities.