These are tax regulations referring to the tax treatment of a company held overseas. (For example, the profits of a foreign subsidiary may, for tax purposes, be "deemed" distributed to the shareholding company whether a dividend is actually paid or not.)

http://verdunlegal.com/index.php?option=com_content&task=vie...
"Today CFC (controlled foreign company) regulations have been implemented by most western high-tax countries.

Though both the scope of the regulations and the consequences of being considered a CFC differ from jurisdiction to jurisdiction, the fundamental object of the regulations is always to prevent residents setting up and keeping profit in companies in low tax jurisdictions.

A company may fall within the scope of CFC, either based on the control of the company exercised by residents or by beneficial ownership, or a combination of both, depending on the jurisdiction."