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 Forecourts Address and Phone Number Special Civil 2022-2025

Cn 11808 2022-2025 Form

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the Section 965 transition tax applies to foreign corporations referred to as specified foreign corporations a specified foreign corporation means any CFC and any foreign corporation with respect to which one or more domestic corporations is a u.s. shareholder for 2017 a u.s. shareholder is a u.s. person that owns within the meaning of section 958 a or is considered as owning under the constructive ownership rules of section 958 be 10% or more of the voting shares of a foreign corporation under Section 958 a stock is considered owned by a person if it is owned directly or if it is owned indirectly through certain foreign entities under Section 958 B section 318 attribution rules apply with certain modifications to the extent that the effect is to treat any u.s. person as a u.s. shareholder section 318 a 2 provides rules attributing ownership upward from entities to its owners section 318 a 3 provides rules attributing ownership downward from owners to entities for example section 318 a

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