CFC rules are applied to the following entities:  1) A trust located abroad as long as the Argentine resident manage its assets. As examples of the existence of this management can be mentioned:   a) When the trust is revocable trust.  b) When the trustor and the trust’s beneficiary are the same person.  c) When the Argentine resident has the right to directly invest or the assets of the trust.  2) An entity which is not considered taxpayer in the foreign country, that is to say, its profits are directly assigned to the Argentine resident.  3) An entity which is considered taxpayer in the foreign country, as long as some requirements take place concurrently. These requirements are:  a) The Argentine resident control, directly or directly, the entity located in the other country. b) The non resident entity does not have the material and human resources to perform its activity or its passive and portfolio income are equal or greater than 50% of the entity profits, or its profits result on deductible expenses for related parties in Argentina. c) The income or profits mentioned in b) are taxed at a rate below than 75% of the rate at which those income or profits would have been taxed in Argentina, or the entity in question is located in a non-cooperative or low or no tax jurisdiction or country.  In order to determiner the condition mentioned in a), i.e. if the Argentine resident controls the entity located in other country, one of these cases has to take place:  a) The Argentine resident, directly or indirectly, owns 50% or more of the foreign entity net worth or profits. b) The Argentine resident, directly or indirectly, has 50% or more of the votes for taking decisions in the foreign entity. c) The Argentine resident, directly or indirectly, has the right to manage and sell the entity goods and properties. d) The Argentine resident, direct or indirectly, has the votes to appoint the board of directors of the entity. e) The Argentine resident takes part in the board of directors and has in it the votes to impose decisions. f) The Argentine resident, directly or indirectly, has the votes to dismiss the CEO or managers of the entity. g) The Argentine resident has any right on the entity profits. h) At least 30% of the value of the entity assets arises from financial investments that generate passive income from Argentine source. i) Passive and portfolio income obtained by the entity is taxed at a rate below than 75% of the rate at which those income would have been taxed in Argentina.  As regards indirect control, it takes place when the Argentine resident controls the foreign entity (i.e. one of the facts listened above takes place) through one of these means:  a) An entity which is controlled by the Argentine resident. b) Argentine resident’s relative (e.g.: spouse). c) The person who cohabits with the Argentine resident.  