Controlled Foreign Company rules: attributable income included based on shareholding, holding period and specified income computation. The Schedule requires inclusion in a resident's total income of an amount attributable to a Controlled Foreign Company, computed by applying a formula that multiplies the CFC's specified income by the assessee's higher percentage of capital or voting interest and by the ratio of days the interest was held to the days the company was a CFC; specified income is net profit adjusted for provisions, interim dividends and prior losses and prorated to the days the company is a CFC.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Controlled Foreign Company rules: attributable income included based on shareholding, holding period and specified income computation.
The Schedule requires inclusion in a resident's total income of an amount attributable to a Controlled Foreign Company, computed by applying a formula that multiplies the CFC's specified income by the assessee's higher percentage of capital or voting interest and by the ratio of days the interest was held to the days the company was a CFC; specified income is net profit adjusted for provisions, interim dividends and prior losses and prorated to the days the company is a CFC.
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