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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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