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That's a bit strong. There are many reasons for setting up an offshore company in a foreign jurisdiction. As long as the returns are properly reported it is not a sham.

I had a property owning company in the UK doing exactly this. It was classed as a CFC and I had to pay tax on the increase in value every year (the balance sheet was used for this purpose as all UK limited companies have to be audited). This was a pain when the AUD dropped as in AUD terms the...