Corporate Tax

February 09 2018
Sandra P McGill GILTI rules particularly onerous for non-C corporation CFC shareholders

USA - McDermott Will & Emery

The recently enacted tax reform legislation significantly expanded the application of Subpart F, adding a new inclusion rule for non-routine controlled foreign corporation (CFC) income, termed global intangible low-taxed income (GILTI). The GILTI rules apply higher tax rates to GILTI attributed to individuals and trusts that own CFC stock than to C corporation shareholders. There are several steps which individuals and trusts may take to defer or reduce the effect of the GILTI rules on individuals and trusts.

Authors: Sandra P McGill, Gary C Karch, Kevin J Feeley, Susan O'Banion
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Recent updates

Mareli Treurnicht A win against SARS: late delivery of Rule 31 statement

South Africa - Cliffe Dekker Hofmeyr

Author: Mareli Treurnicht
Valery Narezhniy Additional tax reports required from Russian divisions of international companies

Russia - Gorodissky & Partners

Author: Valery Narezhniy
Omar Morales Defining permanent establishments for tax purposes

Chile - Montt y Cia SA

Author: Omar Morales
Maurus Winzap Initial coin offerings – more clarity on tax implications

Switzerland - Walder Wyss

Authors: Maurus Winzap, Peter Hongler
Philippos Aristotelous Further extension for applications to settle tax arrears by instalments

Cyprus - Elias Neocleous & Co LLC

Author: Philippos Aristotelous
Aki Corsoni-Husain Tax information exchange: an overview

British Virgin Islands - Harney Westwood & Riegels

Authors: Aki Corsoni-Husain, Mirza Manraj
Thomas W Giegerich US tax reform measures affecting foreign multinationals

USA - McDermott Will & Emery

Authors: Thomas W Giegerich, Kristen E Hazel, Sandra P McGill, Barry J Quirke
David Davies Tax loss transactions denied

Canada - Thorsteinssons LLP

Author: David Davies

Upcoming event

ABA Section of International Law 2018 Annual Conference

April 17-21 – New York City

We look forward to welcoming you in New York for the American Bar Association (ABA) Section of International Law’s 2018 Annual Conference, to be held at the Grand Hyatt New York. The theme of the conference is “At the Crossroads: The Fusion of Private and Public International Law”. This multi-day event will provide a one-stop shop where you can get your Continuing Legal Education (CLE) credits, partake in exceptional networking opportunities with expert professionals and listen to keynote addresses from our outstanding luncheon speakers. The conference will kick off on Tuesday, April 17 with a day of skills programmes. Our reception venues include The Rainbow Room and Bryant Park Grill. The Annual Conference is a ‘must-attend’ meeting for lawyers with a practice or interest in international legal issues. The Annual Conference is a “must-attend” meeting for lawyers with a practice or interest in international legal issues.

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