The U.S. IRS has published a practice unit on the IRC 958 Rules for Determining Stock Ownership. The general overview of the practice unit includes the following: The objective of the subpart F provisions is to provide anti-deferral rules for certain foreign source income that is derived by certain foreign corporations by requiring certain U.S. persons to currently include the income as it is earned by the foreign corporation. The subpart F provisions cover passive income such as foreign base company income [IRC 954], investment in U.S. property [IRC 956], and global intangible low-taxed income ("GILTI") [IRC 951A]. Internal Revenue...