Russia Clarifies Determination of Ownership in CFCs
The Russian Ministry of Finance has published Letter No. 03-03-06/1/68011, concerning the determination of ownership in a controlled foreign company (CFC). One of the key points of the letter is clarification regarding the date on which the ownership threshold must be met in order for a Russian taxpayer to be recognized as a controlling person of a CFC.
Under the CFC rules, a Russian taxpayer …
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