GILTI rules address income subject to high foreign tax rate
To cater the provision of global intangible low-taxed income (GILTI), IRS issued an additional package Sec. 951A, which was added by the law known as the Tax Cuts and Jobs Act, P.L. 115-97. It requires 10% US shareholders of controlled foreign corporations (CFC) to include in their gross income as their share of the CFC’s GILTI […]
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