Make sure your clients are aware of the potential consequences of having stock in a CFC as part of their estate.
A foreign corporation is a CFC if greater than 50% of the stock by vote or value of it is owned, directly, indirectly, or constructively, by U.S. shareholders on any day of its tax year. Before the Tax Cut and Jobs Act of 2017 only voting shares of stock that the U.S. person owned were taken into consideration. This allowed clients to avoid U.S. shareholder status by holding only non-voting stock. The TCJA eliminated this planning strategy, however, by requiring a U.S. person’s non-voting shares of stock be counted to determine the person’s U.S. shareholder status. This white paper reviews the definition of a CFC and what constitutes a U.S. shareholder and discusses attributions of ownership as well as consequences of CFC status.
Anthony F. Vitiello, Esq.
Connell Foley LLP
- Partner and chairman of the Taxation and Estate Planning Group of Connell Foley LLP (Resident in the Roseland, NJ office)
- Practice is dedicated to sophisticated tax planning for individuals, businesses, estates and trusts, with a particular emphasis on national and multinational estate planning, as well as as-set protection planning
- Lectures extensively and frequently publishes in legal and business journals on a variety of tax and estate planning issues, including those related to federal estate, gift and income tax issues, wealth preservation, trusts, and a multitude of other planning techniques
- Admitted to practice in six states, the District of Columbia and United States Tax Court
- Recognized for the past 10 years in “Best Lawyers in America” in the areas of trust and estates, trust and estates – litigation, and tax litigation and controversy
- LL.M. degree in taxation; J.D. degree, New York University
- Can be contacted at 973-840-2433 or [email protected]
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