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Etiket 'non resident alien tax withholding' (2)

Federal Tax Reform’S Repatriation Transition And Gilti Tax

shareholder" of one or more CFCs to include in income, on a current basis, its GILTI in a manner similar to subpart F income. The Global Intangible Low-taxed Income is a new provision, enacted as a part of tax reform legislation. Mechanically, it functions as a global minimum tax and introduces a lot of issues for all U.S. shareholders of controlled foreign corporations – especially individuals and partnerships.Applies broadly to certain income generated by a controlled foreign corporation ....

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International Tax Planning Cpa

Our international tax lawyers have detailed knowledge of the U.S. federal income tax laws applicable to both outbound investments and activities of U.S. taxpayers and inbound investments and activities of foreign taxpayers. For outbound investments and activities of U.S. taxpayers, the applicable U.S. federal income tax laws include the foreign tax credit, anti-deferral, outbound transfer and dual consolidated loss rules. International Financial Reporting Standards are critical to understand...

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