The GILTI provisions in the Tax Cuts and Jobs Act are intended to curtail tax avoidance by multinational corporations and keep them from relocating their tax domiciles abroad.
Before the tax reform, income from a foreign corporation was taxable for a U.S. person only if it was received as a dividend. Now, shareholders of controlled foreign corporations (CFC) with 10% ownership must include their portion of the foreign income on their personal tax returns. The IRS defines a controlled foreign corporation as any foreign corporation in which U.S. shareholders have more than 50% of the control or more than 50% of the value.
Certain taxpayers and all CFC’s will be impacted by the GILTI rules and its important to review the implications GILTI. At American Expat Tax we will provide an overview of the regulations and their intent, define the new terms in the regulations, calculate GILTI, demonstrate how the regulations affect entities and individuals differently, and what strategies are available to mitigate potential tax consequences. Contact us at 888-243-9992 or firstname.lastname@example.org.