Systems with controlled foreign corporation rules may provide deemed paid credits with respect to deemed income inclusions under such rules.

We do not think this an abridgment of the right of a foreign corporation to sue.

Active income also excludes all income of a foreign corporation lacking sufficient substance.

Corporations may reincorporate into a low-tax company through reversing a merger with a foreign corporation (inversion similar to a reverse merger).

The constitution requires the foreign corporation to have one or more known places of business in the state before doing any business therein.