Provisional Measure 627/2013 (PM 627/2013), published in the Official Gazette of 12 November 2013, introduced important changes to the Brazilian tax legislation. Among those changes, PM 627/2013 introduced CFC rules for resident individuals holding participation in foreign entities.
According to the new CFC rules, foreign profits derived by resident individuals are considered available on the date of the foreign entity's balance sheet, regardless of actual distribution, and are subject to indivi…