On 16 May 2016, the Lower Level Federal Judicial Court of Curitiba issued a decision holding that the provisions of Art. 76 of Law 12.973/2014, which contain the Brazilian CFC rules, are unconstitutional. Under the rules, Brazilian companies must add a pro rata share of the profits of their foreign CFCs to their taxable income as on 31 December of the relevant fiscal year, regardless of any act…