International Tax Lunch: Guide to Global Intangible Low-Taxed Income (Section 951A)

Description

U.S. shareholders of foreign corporations have a new pass-through income category to contend with: GILTI. Except for capital-intensive companies, this has the effect of making foreign operating income immediately taxable to U.S. shareholders. What is GILTI? This session explores the rules, how it affects U.S. shareholders and available countermeasures.

Highlights

• Section 951A
• U.S. shareholders of foreign corporations

Objectives

• Identify Section 951A rules and filing requirements
• Determine whether foreign income is susceptible to GILTI requirements

Designed For

CPAs and attorneys