A foreign corporation is a CFC when more than 50 percent of the voting power or value of its shares is owned by “U.S. shareholders”. A “United States shareholder” is generally a US person owning 10% or more of the voting power of the corporation. US shareholders of a CFC are taxed on a current basis on certain types of income (generally referred to as “Subpart F” income) earned by the CFC even though the CFC has not made an actual distribution to the shareholder. Furthermore, this income is taxed at ordinary income rates even if it would have been treated as capital gain (possibly taxed at lower tax rates) had it been earned directly by the shareholder.