Controlled Foreign Corporation

Controlled foreign corporation (CFC) rules are features of an income tax system designed to limit artificial deferral of tax by using offshore low taxed entities. The rules are needed only with respect to income of entities that is not currently taxed to the owners of the entity. The basic mechanism and details vary among jurisdictions. Generally, certain classes of taxpayers must include in their income currently certain amounts earned by foreign entities they or related persons control. A set of rules generally define the types of owners and entities affected, the types of income or investments subject to current inclusion, exceptions to inclusion, and means of preventing double inclusion of the same income. Countries with CFC rules include, but are not limited to, the United States (since 1962), the United Kingdom, Germany, and Japan. The rules of each of these four countries bear significant differences.