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Constructive ownership and the meaning of control for CFC purposes by Lucas de Lima Carvalho

By: Carvalho, Lucas de Lima.
Material type: ArticleArticleSubject(s): SOCIEDADES EXTRANJERAS CONTROLADAS | IMPUESTOS | AMERICA LATINA In: Tax Notes International v. 113, n. 2, January 8, 2024, p. 175-187Summary: This article emphasizes the significance of control in the taxation of controlled foreign corporations (CFCs), examining the conventional meaning of the term and its relevance to its utilization in tax legislation.
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This article emphasizes the significance of control in the taxation of controlled foreign corporations (CFCs), examining the conventional meaning of the term and its relevance to its utilization in tax legislation.

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