Controlled Foreign Corporations: Is “Control” a Good Thing?
Generally, under the tax rules of many countries – including the U.S. – a shareholder of a corporation is not taxed until income is distributed as a dividend. This can result in a potential deferral of tax by using offshore entities located in low-taxed or no-tax jurisdictions. The U.S. has enacted anti-deferral rules intended to change the current taxation of certa [...]
