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Foreign Profits and CFCs

Masahiro Murashima of Kitahama Partners discusses global approaches to foreign source profits and controlled foreign company legislation
In June 2007 the UK Government announced its proposal to reform taxation shifting towards an exemption method on distributed profits from controlled foreign companies (CFCs) located in another jurisdiction1. At around the same time the US Treasury Department revealed its plan to change the tax system on foreign profits.2 Japan also introduced reformed tax legislation3 in 2009 shifting towards an exemption method on dividend distribution. Thus those economic giants showed a common intention to reform their tax systems on foreign profits. Accordingly it would be interesting to analyse reasons behind those reforms in the context of tax competition in the global economy at present. Interestingly the comparative study of tax systems in those...

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