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Vol 2 No 3CFC
01 Nov 1990

TIB - November 1990 appendix CFC

  • Introduction
  • Overview of CFC legislation
  • Interpretation
  • Associated persons
  • Controlled foreign company definition and calculation of control interests
  • Calculation of income interests
  • Variations in control or income interests
  • Persons not required to calculate attributed foreign income or loss
  • Attribution of income and losses
  • Aggregate income interests greater than 100 percent
  • Change of CFC's accounting date
  • Branch equivalent income or loss
  • Foreign tax credits
  • Attributed foreign losses
  • Changes of residence of controlled foreign companies
  • Controlled foreign companies resident in fifteenth schedule countries
  • Residence of a company
  • Administrative provisions
  • Transitional rules
  • Relationship of CFC regime to other provisions