- NY Credits : 2.0
- TX Credits : 2.0
- IRS Enrolled Agent Credits : Federal Tax/Tax Related Matters - 2.0
- IRS Non-Credentialed Return Preparer Credits : Federal Tax - 2.0
The New International Tax Regime: Nothing to Feel GILTI About New
The 2017 Tax Act introduced a lot of changes to the Internal Revenue Code, but arguably none bigger or more important than the introduction of Global Intangible Low Tax Income (“GILTI”), which has turned completely up-side-down the US taxation of offshore business activities conducted through controlled foreign corporations (“CFCs”).
GILTI – notwithstanding its name -- is actually NOT a tax on “intangible income” in low tax jurisdictions, but rather a US income tax imposed on all income of a CFC, minus a (relatively paltry) allowable amount, where the CFC income has not been taxed by the home jurisdiction at a tax rate of at least 13.125%. In such cases, the US basically steps in and takes the position that, “Heck, if no one else is going to tax that income, we will!”
The GILTI rules works pretty effectively for US corporations engaged in foreign operations through CFCs, imposing a very reasonable US tax of no more than 10.5%. However, these same rules do not work well at all for US individuals, S-corporations and partnerships that own CFCs – in fact, the tax results will be positively brutal unless and until the situation is addressed and restructured.
This webinar will provide the good, the bad, and the ugly regarding the GILTI Regime, and will examine various ideas and strategies on how best to manage its curious and quirky provisions.
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