Christine Hradsky No Comments

Own a CFC? Get Ready to be GILTI…

There have been many changes in the last 12 months for US taxation of foreign entities. US shareholders of controlled foreign corporations (CFCs) have already felt the pinch of transition tax for 2017. Unfortunately, the pinch of foreign taxation changes is going to continue in 2018 and onwards thanks in part to GILTI. As the acronyms connotation implies, it is a less than popular tax change. Let us look together at some significant points related to the ominous GILTI: Read more

Christine Hradsky No Comments

International Tax Technical Update- October

TREASURY ISSUES PROPOSED REGULATIONS FOR GLOBAL INTANGIBLE LOW-TAXED INCOME, SECTION 951A

Summary

On September 13, Department of the Treasury and the Internal Revenue Service (collectively, Treasury) issued proposed regulations (REG-104390-18, hereinafter, the Proposed Regulations) implementing Section 951A. Read more

Christine Hradsky No Comments

The GILTI Effect: Tax Reform And Global Intangible Low-Taxed Income

What is GILTI?
The Global Intangible Low-taxed Income (GILTI) is a new provision, enacted as a part of tax reform legislation. Mechanically, it functions as a global minimum tax and introduces a lot of issues for all U.S. shareholders of controlled foreign corporations (CFCs) – especially individuals and partnerships. Read more