Controlled foreign corporation information

Controlled foreign corporation (CFC) rules are features of an income tax system designed to limit artificial deferral of tax by using offshore low taxed...

taxed; however, these nations typically scrutinize foreign income with controlled foreign corporation (CFC) rules to avoid base erosion and profit shifting...

Foreign personal holding company income (FPHCI) is defined for U.S. controlled foreign corporation rules and, with modifications, for U.S. foreign tax...

application in the case of U.S. Shareholders of controlled foreign corporations. Any foreign (i.e., non-U.S.) corporation meeting either the income test or the...

incorporation, an IBC or its owners, if resident in a country having “controlled foreign corporation” rules for instance, can be taxable in other jurisdictions....

such as the controlled foreign corporation (CFC or Subpart F) rules and the passive foreign investment company (PFIC) rules that subject foreign earnings...

underlying the income recognized by the member. Systems with controlled foreign corporation rules may provide deemed paid credits with respect to deemed...

The Protecting Americans from Foreign Adversary Controlled Applications Act (PAFACA) is an act of Congress that was signed into law on April 24, 2024,...

deductions from US Federal Government employees Controlled foreign corporation, company owned or controlled primarily by taxpayers of a different jurisdiction...

allows foreign income to be left in foreign subsidiaries (deferring U.S. taxes), but it will consider BER1 to be a controlled foreign corporation (or "CFC")...

deposited in a controlled foreign corporation offshore, preferably in a tax haven where minimal records are kept, and then shipped back as a foreign direct investment...

by a foreign corporation to a U.S. corporation. This happens often where the foreign corporation is considered a "controlled foreign corporation" (CFC)...

currently on the income of its controlled subsidiary companies managed and controlled outside the UK which are subject to "low" foreign taxes. Low tax is determined...

Irish corporation tax ("CT") receipts to the Irish Exchequer were: Foreign firms pay 80% of Irish CT Revenue (notwithstanding that large U.S.–controlled tax...

A foreign direct investment (FDI) refers to purchase of an asset in another country, such that it gives direct control to the purchaser over the asset...

corporations in Canada. Assets of foreign-controlled corporations rose 8.3% to $1.1 trillion in 2004, while those of Canadian-controlled corporations...

and Gaming Corporation (PAGCOR, Filipino: Korporasyon sa Libangan at Palaro ng Pilipinas) is a government-owned and controlled corporation established...

applications. Dongfeng Motor Corporation (DFM) is the ultimate parent company using the Dongfeng name and is directly controlled by the State-owned Assets...

privatization as part of a laissez-faire policy. A corporation is, at least in theory, owned and controlled by its members. In a joint-stock company the members...

on corporation accumulations in excess of business needs, Personal holding company taxes, Passive foreign investment company rules, and Controlled foreign...

examinations Advance pricing and cost sharing agreement administration Controlled foreign corporation examinations Thin capitalization General anti-avoidance On September...

government-owned and controlled corporation responsible for providing postal services in the Philippines. The Philippine Postal Corporation has in excess of...

are shareholders of controlled foreign corporations must file Form 5471 with respect to each such controlled foreign corporation. Penalties for failure...

Okrug, Moscow. Many of the corporation's assets are located in various regions in Russia, with joint-ventures with foreign partners in Italy, India and...

Refrigerator Co. in 1984. With China opening up to world markets, foreign corporations began searching for partnerships in China. One of these, Germany's...

The Foreign Exchange Management Act, 1999 (FEMA), is an Act of the Parliament of India "to consolidate and amend the law relating to foreign exchange with...

forced the closing of most foreign exchange markets." in The outlook: Volume 45, published by Standard and Poor's Corporation – 1972 – Retrieved 15 July...

venture between the Nigerian federal government and a number of foreign multinational corporations, which include Royal Dutch Shell, Agip, ExxonMobil, TotalEnergies...