The Supreme Federal Court (STF) of Brazil resumed its judgment in the case set to decide the constitutionality of the country’s controlled foreign company (CFC) rules yesterday and confirmed an injunction meaning mining multinational Vale will not have to pay its R30.55 billion ($15.09 billion) tax assessment until the court has made further analysis.
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The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
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