You own part of a company in another country. The company earns money, but it hasn’t paid you any dividends. Do you have to pay U.S. tax on that income right now, even though you haven’t received it? In international tax, the answer is often yes. This chapter explains the rules that stop U.S. shareholders from stashing income in low‑tax foreign companies and delaying U.S. tax forever. We’ll look at what makes a foreign company “controlled,” which types of income get taxed right away, and the safeguards that keep things fair.