Internal structure in CFCs If you're a U.S. person who owns (or has a stake in) a company incorporated outside the United States, three terms should be on your radar: Controlled Foreign Corporation (CFC), Subpart F income, and GILTI. These rules exist to prevent U.S. shareholders from parking profits offshore indefinitely — and they can generate a current U.S. tax bill even if you never see a dividend from the foreign company. This week, we're breaking down how these three pi