Summary
The U.S. Tax Court considered whether Framatome’s subsidiary, Burndy-US’s 50% interest in Burndy-Japan was qualified to be treated as a controlled foreign corporation (CFC) for tax purposes.
Framatome Connectors USA, Inc., et al. v. CIR
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The U.S. Tax Court considered whether the 50% interest Framatome’s subsidiary, Burndy-US, had in Burndy-Japan was qualified to be treated as a controlled foreign corporation (CFC) for tax purposes.