Framatome Connectors USA, Inc., et al. v. CIR
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.
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.