By Saren Goldner, Mary Monahan and Kristan Rizzolo (October 19, 2018, 11:22 AM EDT) -- Prior to the Tax Cuts and Jobs Act,[1] U.S. companies typically structured their minority investments in non-U.S. corporations to limit the risk that the controlled foreign corporation, or CFC, rules would apply. Companies worked through the attribution rules and, based on those rules, limited their minority investments in non-U.S. corporations so that they would have less than 10 percent of the vote in any one non-U.S. corporation. The ultimate goal was to avoid being U.S. shareholders, within the meaning of Section 951(b) of the Internal Revenue Code of 1986, of CFCs of which, in reality, they had no control. However, as of Jan. 1, 2018, all of that careful planning may have been upended. This article provides a practical approach to evaluating ownership of non-U.S. entities under the new Subpart F rules and to dealing with the consequences of becoming a U.S. shareholder in a CFC in which you have no control....