A CFC is a foreign resident company where a control test is satisfied (see below). First criteria: whether the CFC is a resident of a listed (Canada, France, Germany, Japan, NZ, UK, US) or unlisted country (all other countries). Second criteria: one of the three control tests must be satisfied. In particular: - Strict control: a group of five or fewer Australian 1 per cent entities and their associates hold at least 50 per cent (direct and indirect interests) of the foreign company. - Assumed control: a foreign company owns or is entitled to acquire an associate-inclusive control interest of at least 40 per cent in the foreign company. - De facto control: a group of five or fewer Australian entities, either alone or with associates, effectively controls the foreign company.