Andrew Boucher looks at what the controlled foreign companies reforms mean in practice
This article looks at how the rules work and what they may mean in practice for groups. I have concentrated on the elements of the rules that introduce new concepts or where there may be particular practical issues. So although this not supposed to be a complete guide I hope it will help giving those issues some focus. In the interest of column inches I am not dealing with how the regime is modified for banking and insurance business.
Before we even get into the new rules it’s worth noting that the definition of CFC and control has changed. The new control definition in TIOPA 2010 new s 371RA et seq enlarges the existing definition and...
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