EFTA Document EFTA01382997

GLDUS238 SOUTHERN FINANCIAL LLC Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined voting power or total value of all classes of stock of a non-U.S. corporation (each, a "United States Shareholder") that is a "controlled foreign corporation" ("CFC'). A non-U.S. corporation generally will be a CFC if United States Shareholders collectively own more than 50% of the tota