The CFC rules are designed to remove tax deferral advantages that could previously be obtained by setting up companies in foreign jurisdictions by taxing Australian resident shareholders who control foreign companies on 'tainted' income earned by the foreign companies in the relevant income year. explain how the CFC rules operate including the 5 steps involved in calculating the amount of attributable income of a CFC pursuant to s.456 ITAA36.

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The CFC rules are one of the measures to curb the practice of artificial deferral of income CFC rules generally deeming in nature and are applied to a... View the full answer