Controlled foreign corporations
(ii) Controlled foreign corporations. A section 1296 election by a CFC shall be made by its controlling United States shareholders, as defined in 1.964-1(c)(5), and shall be included with the Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, for that CFC by the due date (including extensions) of the original income tax returns of the controlling United States shareholders for that year. A section 1296 election by a CFC shall be binding on all United States shareholders of the CFC.