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 (either directly or through LLCs or S corporations) than to C corporation shareholders. This article describes the difference and suggests steps individuals and trusts may take to defer or reduce the effect of the GILTI rules on individuals and trusts.
GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders
Posted In Tax Reform, Uncategorized
Gary C. KarchGary C. Karch advises clients on the federal income tax aspects of partnership and limited liability company transactions, including acquisitions, investments, joint ventures and restructurings. Gary is also a certified public accountant. Read Gary Karch's full bio.
Kevin J. FeeleyKevin J. Feeley focuses his practice on the taxation of complex transactions, with particular emphasis on structuring and implementing partnership and limited liability company transactions, including joint ventures and private equity investments. In addition, Kevin has extensive experience in structuring mergers and acquisitions, tax-free reorganizations, recapitalizations and restructurings of financially troubled companies. He also has advised closely held companies, family offices, S corporations and cooperative organizations on tax planning issues and strategies. Read Kevin Feeley's full bio.
Sandra P. McGillSandra McGill focuses her practice on international tax planning. Sandra works with US and non-US multinational companies, public and private as well as high net worth individuals and family businesses. Sandra has extensive experience advising clients on a broad range of cross-border tax issues. Read Sandra McGill's full bio.
BLOG EDITORS
STAY CONNECTED
TOPICS
ARCHIVES
