I am just highlighting the fact that CFC rules are quite often irrelevant, and people tend to overestimate their impact at times.
More important are the domestic tax laws for determining the corporate tax residence and the concept of permanent establishment.
The end result is largely the same though, so there is little point to nitpick about it.
Lol.,,,what has an association got to do with the thread? If you want to say CFC rules are often irrelevant as I said you need to look at thresholds before they apply. But if you say they are not relevant whatsoever then good luck. PE does not happen in a vacuum you need to look at the DTA if one exists to determine this. It's simply facts I am telling you but you dont have to agree...lol.