Private Equity Firms May Eye Offshore Investing Under ‘GILTI’ Relief

June 25, 2019, 8:45 AM

U.S. shareholders with small interests in private equity and venture capital firms could be safe from a tax on a new category of foreign income under proposed IRS rules, which might spur cross-border investment.

The Internal Revenue Service offered a reprieve to certain shareholders of partnerships on the tax overhaul’s levy on global intangible low-taxed income, designed to curb multinationals from shifting profits out of the U.S. tax base.

Proposed (REG-101828-19) and final rules (T.D. 9866) narrow the reach of the GILTI tax by eliminating the hit on certain individual shareholders.

Those shareholders must ...

To read the full article log in. To learn more about a subscription click here.