Headquartered in London and backed by Lloyd's, CFC
serves more than 70,000 businesses in over 80 countries.
group election is irrevocable and must be consistently applied to all CFCs
, including any subsequently acquired CFCs
Fitch views CFC
's economic access to diversified funding sources favorably.
The categories of excluded gross income (ignored in calculating the tested income or loss of a CFC
for a CFC
inclusion year) are:
Companies targeted by CFC
are typically involved in: fifinancial services (except retail banking); professional services (law fifirms, accountants etc); African holdings; or are regional headquarters of multinationals.
Member investments and equity total roughly 20 percent of CFC
's total debt funding.
Consideration of future consequences scale (CFC
, which specialises in anti-slip vinyls and wetroom flooring alongside standard carpet and tiling products, was established by Keith Barnes in Queensway Court, on East Middlesbrough Industrial Estate.
Individual differences in the CFC
are defined as "the extent to which people consider the potential distant outcomes of their current behaviors and the extent to which they are influenced by these potential outcomes" (Strathman et al.
The question of whether a controlled foreign corporation (CFC
) may enter into a contract manufacturing arrangement while still meeting the manufacturing exception to the FBCSI rules has been a matter of contention between taxpayers and the IRS for over three decades.
Notice 2008-91 extends the exception for loans held by the CFC
that are repaid within 60 days from the time incurred (and allows the CFC
to elect to exclude them under section 956 from the definition of "obligation"), as long as the CFC
does not hold obligations that would be investments in U.S.
As well as Standard Bank of South Africa and the Industrial and Commercial Bank of China (ICBC) having received the necessary regulatory and shareholder approval to proceed with their $4.8bn tie up, Standard Bank has also finalised the recent merger of its subsidiary Stanbic Kenya with Kenya's CFC
Bank in a KSh19bn ($279m) transaction.