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Following up on the Sub-year offshore company, I present the accrued deficit CFC company. Similarly to how profits have different values based on the CIT in a given country, so does accrued deficits. When a company becomes a CFC company for a given owner, some accrued deficits might be taken...

A lot of countries have currency restrictions, including countries like China. We know that smart money is leaving China and will stay in USD for example (or CHF), but how do people get money out? Currency restrictions like this exist in many countries all over the globe. For example, assume a...

I see a lot of CFC laws that in order to simplify the definition of ownership, defines ownership at the end of the tax year only. This is interesting as it seems CIT of 0% is then possible by simply not owning the company at the end of the year. This creates dividends or capital gains that must...