Excessive tax burden contributes to tax evasion. The level of development of the shadow economy depends on the level of the tax burden Many entrepreneurs leading international activities, move their business or it‘s parts in the countries with the lowest tax burden. Most states strictly control the activities of their companies in offshore areas. At the moment, Russia has agreements on avoidance of double taxation with 80 countries. On March 18, 2014 the Ministry of Finance of the Russian Federation according to the plan for a de-offshoreization of the Russian economy published a bill that enforces the rules of controlled foreign companies (CFC) in the Russian Federation. In the article analyzes the major issues of this bill.