[buzer]

> The reason that publicly-traded companies are not CFCs is that a CFC must have 50% of the vote or value of the company owned by US Shareholders.

Aren't there some public companies where some people have over 50% of the votes? Facebook comes to mind as one. Or are their international subsidiaries designated as CFCs?

[gnicholas]

You're right, it looks like Zuck has 60% of the voting power of FB. [1] I wouldn't be surprised if FB's tax lawyers came up with a creative way to structure their international operations so that not all of their foreign subs are CFCs.

1: https://www.vox.com/recode/2019/5/30/18644755/facebook-stock...