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Tax Cuts and Jobs Act offshoring Controlled Foreign Corporation rules around the world CFC rules US CFC rules passive foreign investment companies, PFICs GILTI, global minimum tax

How Controlled Foreign Corporation Rules Look Around the World: United States of America

The United States was the first country to enact CFC rules, and it is probably the country with the most complex set of rules that will be presented in this blog series. The rules determine control using a combined ownership test: one for the corporation and the other at the shareholder level. The assessable income under the rules is generally passive income but the amount of foreign income subject to U.S. tax has expanded with the adoption of GILTI.

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