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Certificate of Foreign Intermediary, Foreign Flow through Entity, or Certain U Form

Certificate of Foreign Intermediary, Foreign Flow through Entity, or Certain U Form

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Hey scholars, what we're now going to do is we're going to try an exercise that specifically is going to look at things like controlled foreign corporations. We're going to look at Subpart F Income. We're going to look at GILTI, and we're going to look at BEAT. We've got a lot of great stuff to cover, so get ready. All right. Let's take a look at this company. We have Blue Bean Inc. And it purchases a 15 percent interest in Arabica S.A., which is a corporation in Coffeestan. In other words, another country. So therefore, we own 15 percent of them. Well, we've got to do a couple of things here. So if more than  50 percent are U.S. shareholders, we have to examine that. It will be considered a controlled foreign corporation. So let's start out with who owns it. A U.S. person owning at least 10 percent is a factor here. So we're going to take a look at the various people. Let's start. A U.S. citizen or resident, domestic partnership, corporation, estate, or trust, that's what

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