Provisional Measure 627/2013 – CFC rules for resident individuals introduced

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…