Avoiding CFC Status
Under U.S. tax rules, a foreign entity may be classified for U.S. tax purposes as a corporation or a flow-through entity somewhat independently of its classification for foreign purposes. Under these "check the box" rules, shareholders may be able to elect to treat their shares income, deductions, and taxes of a foreign corporation as earned and paid by themselves. This permits U.S. individuals to obtain credits for foreign taxes paid by entities they own, which credits might otherwise not be available.
Artificial arrangements to avoid CFC status may be ignored in some jurisdictions under legislative provisions or court developed law, such as substance over form doctrines.
European civil law may provide opportunities for formalistic agreements whereby practical control is maintained but formal definitions of control are not met.
Read more about this topic: Controlled Foreign Corporation
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