Explore to the U.S. Anti-Avoidance Tax Law—the U.S. Foreign Controlled Company Rules

With the further development of economic globalization, cross-border taxpayers' tax avoidance actions being more and more frequency. Meanwhile the anti-tax-avoidance legislations being an common task both for international tax law and national tax law. the U.S. was the first country conducting anti-tax-avoidance law legislation. Among its anti-tax-avoidance law system, the Foreign Controlled Company Rules was the first CFC rules in the world and being a model for other countries' related legislation. Because more and more transnational tax payers have taken advantages of the Tax Deferral regimes as an tax-avoidance approach, the CFC Rules being dramatically value-gained and its role in the U.S. anti-tax-avoidance law system being more and more significant,while the specific rules are inclined to increasingly severe. Although the U.S. CFC Rules are still confronted with many difficulties and challenges,its anti-tax-avoidance values are still of great research value. In rescent years, China is also facing with severe anti-tax-avoidance missions. Therefore, studying the U.S. related legislations have certain direct and practical significance to China.