CFCs and PFICs.
(2) CFCs and PFICs. For purposes of calculating net investment income, additional rules in 1.1411-10(c) apply to an individual, an estate, or a trust that is a United States shareholder that owns an interest in a controlled foreign corporation (CFC) or that is a United States person that directly or indirectly owns an interest in a passive foreign investment company (PFIC).