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Epstein File EFTA02521579: RICO and Controlled (DS11)

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This document discusses U.S. tax jurisdiction over partnerships, trusts, and corporations domiciled in U.S. territories including Puerto Rico, and addresses Subpart F rules applicable to foreign corporations and their shareholders. The document addresses tax treatment of controlled foreign corporations.

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partnerships, and trusts subject to the jurisdiction of U.S. cou=ts, as well as certain corporations domiciled in certain U.S. territories, as Puerto **Rico**
Excerpt 2
The Subpart F rules to apply to foreign corporations and their shareholders on=y where the corporation meets the definition of a "**controlled** foreign co

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