Last year we brought a controlled foreign companies (CFC) rule into our tax law and the Revenue Commissioners have recently issued detailed guidance on the whole area. In the 2016 movie Sully, Tom Hanks in the lead role says: “Everything is unprecedented until it happens for the first time.” We have done unprecedented with CFC and there’s more to come.
Firstly, and here’s the science bit, a CFC rule taxes a foreign...
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