
Subpart F Income and Controlled Foreign Corporations: Why U.S. Owners Get Taxed on Foreign Profits Before the Cash Comes Home
Subpart F forces U.S. shareholders of a controlled foreign corporation to recognize foreign profits as current-year income, even when no cash is distributed. This guide covers the 10 percent threshold, the four triggering income categories, Section 958 constructive ownership traps, Form 5471 penalties, and how the 2026 OBBBA rewrite (NCTI, restored 958(b)(4), 40 percent Section 250 deduction) reshapes the rules.










