On March 18, 2014, the Ministry of Finance of the Russian Federation (“RF”) has communicated to the public a draft of the Federal Law “On introduction of amendments to Part One and Two of the RF Tax Code (with respect to taxation of controlled foreign companies’ income and enhancement of efficiency of their tax administration)” (the “CFC Bill”). This CFC Bill, if adopted into legislation, will introduce new reporting and tax obligations in connection with the use of qualifying controlled foreign companies in Russia.