Congress introduced the controlled foreign corporation (CFC) rules in 1962 to prevent U.S. taxpayers from deferring federal income tax on income earned in closely held foreign companies, that is, by binding U.S. shareholders to the levels of ownership requirements to recognize certain types of income earned by CFCs regardless of whether these earnings are actually distributed. Like many other anti-deferral regimes, the CFC regime includes ownership attribution rules in accordance with which share