The Controlled Foreign Company regime is viewed as an important anti -avoidance measure, but whether it is compatibility with tax treaties or not is a important issue.

受控外国公司税制作为一种重要的反避税措施，也产生了与税收协定的兼容性问题。

youdao

Because Orascom, an Egyptian company, owns 65% of its shares, the court concluded that it breaks antiquated foreign-ownership rules requiring all operators to be Canadian-controlled.

因为一家埃及公司Orascom拥有其65%的股份。法院下结论说该公司破坏了古老的外国所有权规则：运营商需要是加拿大控制的才行。

youdao

And of course it is trebly true of the cut in the top rate of income tax, the accelerated reductions in corporation tax and the reform of taxation for multinationals based here (the controlled foreign company rules).

BBC: Big business and Treasury capture government

In that same call, Brandner and Mr. X came up with a new scheme, whereby Brandner created a new Panamanian company called Evergreen Capital LLC, and structured that company so that it was controlled and appeared to be owned by a foreign nominee of Brandner.

FORBES: Brandner: Alaska Plastic Surgeon Faces Forfeiture Of $4.656 Million For Undisclosed Offshore Account Used To Attempt To Cheat Ex-Wife