内容提示: international taxation 1Chapter 8 Controlled Foreign Corporation(CFC) RulesA. Controlled Foreign Corporation(CFC) B. Controlled Foreign Corporation(CFC) Rules C. Rules in different countries 文档格式:PPT | 页数:25 | 浏览次数:9 | 上传日期:2023-10-19 22:59:16 | 文档星级: ...
Controlled Foreign Corporation Rules---GeneralCFC rules: rules that require the passive income and certain other tainted income of foreign corporations controlled by resident shareholders to be included in the income of those shareholders, whether or not such income is distributed.The reason of this ...
Debbie Ann Gordon.“Controlled foreign corporation rules- A proposal for the Carribbean). InterTax . 2004Debbie Ann Gordon.Controlled foreign corporation rules- A proposal for the Carribbean). InterTax . 2004GORDON,DEBBIE ANN.Controlled Foreign Corporation Rules – A Proposal for the Caribbean. The...
We investigate the influence of controlled foreign corporation (CFC) rules on cross-border merger and acquisition (M&A) activity on a global scale. Using three different methods, we find that CFC rules distort ownership patterns due to a competitive advantage of MNEs whose parents reside in non-...
1. CFC rules The principal objective of the CFC rules is to bring to tax in Malta, the profits which are artificially shifted by a Maltese taxpayer to a foreign controlled company. The CFC regulations are applicable as from the basis year starting on or after 1 January 2019. The...
摘要: The author considers the interplay between the new controlled foreign corporation rules in Spain and the EU Alternative Investment Fund Managers Directive, and the light that can be shed on this issue by case law of the European Court of Justice....
英英 n. 1. a corporation whose controlling shareholder is based outside the U.S. 例句 释义: 全部 更多例句筛选 1. The most straightforward way to do so would be to tighten up controlled-foreign-corporation (CFC) rules. 最直接了当的办法是加强受控外国公司规则。 www.ecocn.org隐私...
1.The most straightforward way to do so would be to tighten up controlled-foreign-corporation (CFC) rules.最直接了当的办法是加强受控外国公司规则。 2.A Study of the Conflict between Controlled Foreign Corporations and Tax Sparing Credit;受控外国公司与税收饶让抵免法律冲突研究 ...
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CFC rules vary by country and the criteria to qualify can be stringent. For example, to be determined a CFC In the United States, a foreign corporation must be at least half owned by U.S. shareholders and these shareholders must each hold at least a 10% stake....