International Tax Blog

Update to Video: Global Intangible Low-taxed Income (“GILTI”)

We have updated our YouTube video on GILTI, which we originally discussed here. We had previously believed that GILTI would not apply to a controlled foreign corporation's income that was subject to a foreign tax rate of at least 18.9% (90% of the new U.S. corporate tax rate of 21%). That was incorrect. The foreign tax rate is only relevant to a very narrow exception to GILTI. If a controlled foreign corporation had income that... Read more →

Andrew Mitchel Speaking on "GILTI" at IFA regional meeting

At the next meeting of the Luncheon Series of the International Fiscal Association, USA Branch, Westchester County, NY/Connecticut Region Andrew Mitchel will be the key speaker. The meeting will be held on Thursday February 8th. During the meeting, there will be an in-depth discussion of the new Global Intangible Low-Tax Income ("GILTI") regime imposed by the Tax Cuts and Jobs Act. The meeting is at the Hyatt Regency (in the Pemberwick room) in Greenwich, CT... Read more →

TCJA Explanatory Video: Global Intangible Low-taxed Income (“GILTI”)

Global intangible low-taxed income (“GILTI”) is a new type of income inclusion under the Tax Cuts and Jobs Act. Under the new GILTI rules, a U.S. shareholder of a controlled foreign corporation (“CFC”) must include in gross income for a taxable year its GILTI income in a manner generally similar to inclusions of subpart F income. GILTI means, with respect to any U.S. shareholder for the shareholder’s taxable year, the excess (if any) of the... Read more →