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so essentially, your argument is that it DOES work, but it's just a huge pain in the ass.

I agree whole-heartedly with that- but the bottom line is it does work- you just have to keep everything separate (which is really not that big of a deal).

And the easy to avoid reporting it as a CFC is to not have it be a CFC. If you have a brother/relative from another country, you can each have 50%, and voila! it's not a CFC.

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