Silvania Tognetti, Brazil, Pereira Neto, Galdino, Macedo Advogados ...

CFC Rules
Article 74 of Provisional Measure 2,158-35/ 2001 provided
that the income generated by a foreign controlled or
associated company will be deemed available to the Brazilian
controlling or associated company as of the date of the
balance sheet in which such amounts are reflected, for the
purposes of calculating the bases for the Income Tax (IR) and
the Social Contribution on Net Profit (CSLL).
Note that it applies for all controlled or associated company.
Constitutionality of Article 74 is under review by Supreme
Court.
Superior Court of Justice recognizes the legality of article 74,
but there is recent decision in the sense that profit is not the
equity value of controlled or associated company.