What Is an Expatriated Foreign Subsidiary?

Except as provided in paragraph (a)(9)(ii) of this section, an expatriated foreign subsidiary means a foreign corporation that is a CFC (determined without applying subparagraphs (A), (B), and (C) of section 318(a)(3) so as to consider a United States person as owning stock which is owned by a person who is not a ...

What is an expatriated entity?

An expatriated entity is one that has been acquired by a foreign entity in a country where the business activities are not substantial when compared to those of the affiliated group.

What is a surrogate foreign corporation?

Generally, a foreign corporation is a surrogate foreign corporation if: (i) after March 4, 2003, the foreign corporation acquires substantially all the properties of a domestic corporation or substantially all of the properties constituting a trade or business of a domestic partnership; (ii) after the acquisition, the ...