What next for Brazil’s CFC rules?

Three cases involving taxation on profits earned overseas were recently taken to a plenary session of the Brazilian Federal Supreme Court, but, despite taxpayers’ high expectations of a final position being delivered, the subject remains unsettled. Julio de Oliveira and Erika Tukiama, of Machado Associados, explain what the judgments did clarify and how the unanswered questions will be resolved.