To be a CFC the Korean rules require:    1. With respect to a foreign company, 50% or more of whose voting shares are directly or indirectly held by a Korean resident along with his/her/its specially-related persons, including relatives. The Korean resident holding directly or indirectly 10% or more of shares in such company(including the direct holdings by the specially-related persons) is subject to CFC rules.    2. The foreign company is located in a significantly low tax jurisdiction with an average effective tax rate of 15% or less on taxable income for the past three years.