A CFC is any foreign corporation if more than 50% of the total combined voting power of all classes of stock of such corporation entitled to vote or the total value of the stock of such corporation is owned directly or indirectly by United States shareholders (U.S. shareholder) on any day during the taxable year of such foreign corporation. A U.S. shareholder is defined as a United States person (U.S. person) who owns 10 percent or more of the vote or value of all classes of stock of a corporation. Constructive ownership rules can attribute foreign stock ownership of one person to a related person.