If this email is not displayed correctly please click here

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
Read more

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