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Cliffe Dekker Hofmeyr | South Africa | 5 Apr 2019

Controlled foreign company comparable tax threshold to be decreased

The 2019 Budget noted that a global downward trend in corporate taxation rates may lead to an unintended increase in the imputation of the net income of controlled foreign companies (CFCs) in South African shareholders' taxable income. This could occur despite the fact that at its inception, a CFC has operated in a jurisdiction with tax rates which met the threshold contained in the Income......
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Studio Legale e Tributario Biscozzi Nobili Piazza | Italy | 29 Mar 2019

Impact of Anti-tax Avoidance Directive on Italian CFC legislation

The government recently transcribed the EU Anti-tax Avoidance Directive into Italian law. The decree's new controlled foreign corporation (CFC) rules are applicable from the fiscal year following that in progress on 31 December 2018 (ie, from 2019 for calendar-year taxpayers). The rules introduced by the decree have removed the distinction between a tax haven CFC and a white list CFC.
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McDermott Will & Emery | USA | 9 Feb 2018

GILTI rules particularly onerous for non-C corporation CFC shareholders

The recently enacted tax reform legislation significantly expanded the application of Subpart F, adding a new inclusion rule for non-routine controlled foreign corporation (CFC) income, termed global intangible low-taxed income (GILTI). The GILTI rules apply higher tax rates to GILTI attributed to individuals and trusts that own CFC stock than to C corporation shareholders. There are several......
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Studio Legale e Tributario Biscozzi Nobili Piazza | Italy, Netherlands | 24 Feb 2017

Tax Authority clarifies new CFC rules

The Tax Authority recently issued Circular Letter 35/E, which clarifies Italy's controlled foreign companies (CFC) regime in light of recent changes under Budget Laws 190/2014 and 208/2015 and Decree-Law 147/2015. The black-list criteria provided for CFC purposes have been significantly revised and, if a CFC is deemed to exist, material clarifications have been provided with regard to the......
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Paul Hastings LLP | USA | 11 Nov 2016

Final and Proposed Regulations Address U.S. Property Held by CFCs in Transactions Involving Partnerships

On November 3, 2016, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued final regulations under sections…
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Eversheds Sutherland (US) LLP | USA | 3 Oct 2016

Reversing Course—Proposed Regulations Reverse IRS Ruling Position on Treatment of Income from CFCs and PFICs for RIC Qualification Purposes

On September 27, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (REG-123600-16) (the…
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Morgan, Lewis & Bockius LLP | USA | 30 Sep 2016

IRS and Treasury Issue Guidance Regarding CFC and PFIC Investments by RICs

The recently proposed regulations, if finalized, would govern the treatment of RICs' income inclusions in respect of CFCs and PFICs for purposes of…
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Lee and Li Attorneys at Law | China, OECD | 26 Aug 2016

BEPS-related Tax Law - CFC and PEM Rules

Anti-tax-avoidance has become an important issue among tax authorities in almost every jurisdiction, not least of all in the Republic of China. The…
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Bilzin Sumberg | USA | 26 Aug 2016

Cancellation of CFC Loans to US Shareholders - Should the Service Get a Second Bite at the Apple?

The Service generally has three years after a return is filed to assess any tax due for that year. There are a number of exceptions to this general…
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Beveridge & Diamond PC | USA | 27 Jun 2016

EPA’s Enforcement Focus on Refrigerants Continues With Another Multi-million Dollar Settlement

The U.S. Environmental Protection Agency (“EPA” or “Agency”) continues its enforcement focus on commercial refrigerant leaks from major retailers…
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