Archive: U.S. individual shareholder

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U.S. Individual Shareholders of Controlled Foreign Corporations May Elect to Decrease Tax on GILTI

The Tax Cuts and Jobs Act (TCJA) enacted various U.S. international tax provisions. The new law includes the U.S. federal tax on global intangible low-taxed income referred to as GILTI. The GILTI rule applies to U.S. shareholders of controlled foreign corporations (CFCs). Effective on January 1, 2018, a U.S. shareholder of a CFC is required […]