A Foreign Corporation Is Owned by Five Unrelated Individuals

Multiple Choice

A foreign corporation is owned by five unrelated individuals. John, Sam, and David are U.S. citizens who own 30%, 18% and 9%, respectively, of the foreign corporation's single class of stock. Alberto and Manuel are nonresident aliens who own 37% and 6%, respectively, of the foreign corporation's stock. Which of the following statements is true?

A) There are three "U.S. shareholders" and the foreign corporation is a controlled foreign corporation (CFC) .
B) There are three "U.S. shareholders" and the foreign corporation is not a controlled foreign corporation (CFC) .
C) There are two "U.S. shareholders" and the foreign corporation is not a controlled foreign corporation (CFC) .
D) There are two "U.S. shareholders" and the foreign corporation is a controlled foreign corporation (CFC) .