It is now deemed income for which tax has very probably not been withheld.
2.
Systems with controlled foreign corporation rules may provide deemed paid credits with respect to deemed income inclusions under such rules.
3.
Companies must list cash and commissions, as well as the number of stock options awarded and any perks that can be deemed income.
4.
What is deemed income under tax law sometimes diverges from the way earnings are determined under commercial law, in which case tax law provisions prevail.
5.
CFC rules may have a threshold for domestic ownership, below which a foreign entity is not considered a CFC . Alternatively or in addition, domestic members of a foreign entity owning less than a certain portion or class of shares may be excluded from the deemed income regime.
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