The Offshore Tax Manual - Part 8   - U.S. Taxpayer's Guide for Controlled Foreign Corporations Introduction  Definition of a Foreign Corporation  Definition of a Controlled Foreign Corporation  A Summary Explanation of "Subpart F Income"  Investment Income of Controlled Foreign Corp.  Related Party Purchases or Sales  Related Party Services Income  Other "Tainted Income" (Subpart F Income)  Exceptions to Subpart F Income  U.S. Source Income of Foreign Corporations  CFC Earnings Invested in U.S. Property  Election to be Taxed as a Domestic Corporation  U.S. Corporations with Foreign Operations  Tax Deferral of Non-CFC Income  Tax Treatment of U.S. Stockholders in CFCs  Rules for Passive Foreign Investment Companies  Election to Treat a CFC as a Disregarded Entity  Attribution and Constructive Ownership  Tax on Appreciated Assets Exchanged for Stock  Deemed Royalty on Intangibles  Diverting Profits to a Foreign Corporation  Foreign Tax Credit  U.S. Employee Working and Living Offshore  Ownership of a CFC by a Charitable Trust  Use of an IBC to Avoid Foreign Inheritance Taxes  Withholding on Payments to Foreign Corporation  Foreign Corporation Tax Scams and Schemes  Some Typical Questions We Receive  Tax Filing Obligations of a Foreign Corporation

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