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U.S. shareholders of a CFC must include any subpart F income or GILTI as ordinary income on their individual income tax returns. The current highest federal tax rate applicable to an individual is 37 percent. Individuals receiving GILTI inclusions may also be subject to an additional Medicare tax of 3.8 percent.
A US person who holds at least 10 percent of the stock of a controlled foreign corporation (CFC), will be considered to be a Section 1248 shareholder for US tax purposes. A CFC is defined as a foreign corporation that is owned more than 50 percent by one or more US shareholders.
Section 1248 requires that any gain recognized on the sale or exchange of the stock of a CFC be treated as a dividend to the Section 1248 shareholders to the extent of the E&P of the CFC.
26 U.S. Code § 1248 - Gain from certain sales or exchanges of stock in certain foreign corporations.
It relates to international tax and is income earned within a Controlled Foreign Corporation (CFC) that will be taxed to the U.S. person taxpayers, irrespective of being distributed to the U.S. person taxpayers.
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Africa. April 6 \u2013 Battle of Fariskur: Louis IX (the Saint) is captured by Baibars' Mamluk army while he is in Egypt conducting the Seventh Crusade; he later has to ransom himself. May 2 \u2013 Al-Muazzam Turanshah, Ayyubid ruler of Egypt, is murdered, ending effective Ayyubid Dynasty rule in the country.
26 U.S. Code § 1248 - Gain from certain sales or exchanges of stock in certain foreign corporations.
Seventh Crusade August 12 \u2013 King Louis IX (the Saint) leaves Paris together with his wife, Queen Margaret of Provence, and her sister Beatrice of Provence.
A US person who holds at least 10 percent of the stock of a controlled foreign corporation (CFC), will be considered to be a Section 1248 shareholder for US tax purposes. A CFC is defined as a foreign corporation that is owned more than 50 percent by one or more US shareholders.
26 U.S. Code § 1248 - Gain from certain sales or exchanges of stock in certain foreign corporations.

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