Special rules apply to controlled foreign corporations (CFCs) of U.S. multinationals. The most significant rules unique to CFCs are the Subpart F provisions. This course first discusses the requirements to be a CFC, including ownership requirements and attribution rules relating to the ownership requirements. It then discusses the Subpart F provisions, which will allow the United States to tax certain types of income earned by the CFC currently and not upon repatriation. The course finishes by reviewing the exceptions and limitations of Subpart F income that can be currently taxed.