Individual Shareholders Try to Mitigate Impact of GILTI Tax

June 13, 2018, 9:09 PM

Individual shareholders of a controlled foreign corporation could have a lower effective tax rate in the U.S. by holding stock through a corporation rather than by holding it directly, practitioners said—a “somewhat peculiar outcome” of how the new U.S. international tax rules were drafted.

The tax on global intangible low-taxed income (GILTI) “really illustrates the disparate treatment of individuals and corporations” under the new U.S. tax law, practitioners said June 13 at an American Bar Association event in Miami.

The GILTI of a U.S. shareholder of a controlled foreign corporation (CFC) is generally the U.S. shareholder’s net income from all ...

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