Italy: Lack of Organizational Structure not Decisive to qualify as Conduit bit.ly/2lhfnYk 0 Share this:Click to share on LinkedIn (Opens in new window)Click to share on WhatsApp (Opens in new window)Click to share on Twitter (Opens in new window)Click to share on Facebook (Opens in new window) March 9, 2017 webmaster CFC Rules, Corporate Taxation, Italy, Tax, Tax Planning Controlled Foreign Corporation, Corporate Taxation, Italy, Tax, Tax Planning BVI: VISTA Trusts – An Overview US: Purchase of ADRs not listed on a US Exchange can qualify as “Domestic Transaction”