On 21 June 2007, the Treasury issued a consultation document on the taxation of foreign dividends and the CFC rules. The discussion document suggests the following package of reforms: -   the introduction of an exemption regime for foreign participation (non-portfolio) dividends received by large and medium-sized companies (as defined for EC purposes); -   a simplified foreign tax credit regime for foreign participation dividends received by small companies; -   a new Controlled Companies (CC) regime for large and medium-sized businesses, established on an income basis rather than the "all or nothing" entity basis of the current Controlled Foreign...