Controlled Foreign Corporation - Japan and Other Countries

Japan and Other Countries

Japan taxes shareholders of foreign corporations where the operation of such corporation results in no or minimal foreign tax. However, there is a waiver where the foreign corporation conducts a substantial business. New Zealand and Sweden each have CFC rules, following a "grey list" and a "white list" approach, respectively. Numerous other countries have CFC rules. Australia has CFC rules similar to UK rules, but relies more on a "white list" of safe countries.

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