The Russian Ministry of Finance has published Letter No. 03-03-06/1/68011, concerning the determination of ownership in a controlled foreign company (CFC). One of the key points of the letter is clarification regarding the date on which the ownership threshold must be met in order for a Russian taxpayer to be recognized as a controlling person of a CFC.
Under the CFC rules, a Russian taxpayer is considered a controlling person if directly or indirectly owning more than 25% of the CFC, or mor…