It will be tax, Jim, but not as we know it

A new controlled foreign companies rule is the first of many dramatic legal changes coming down the line

11th August, 2019

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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