GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders

LLCs, U.S. Tax Planning /

Background –  https://www.mooresrowland.tax/2018/02/us-exposed-owner-of-international.html https://www.mooresrowland.tax/2019/01/gilti-regime-guidance-answers-many.html     Summary The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The GILTI rules apply higher tax rates to GILTI attributed to individuals and trusts who own CFC stock […]

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