The Russian Ministry of Finance recently published Letter No. 03-12-11/2/10244, which clarifies the carry forward of losses of a controlled foreign company (CFC). Under Russia's CFC rules, undistributed profits of a CFC are generally included in a Russian resident's tax base if holding at least 25% of the CFC (10% if total Russian holding in CFC exceeds 50%). For this purpose, the profits of th…