Gary C. Karch Gary C. Karch

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Gary 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.

GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders


By , , , and on Feb 1, 2018
Posted In Tax Reform, Uncategorized

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...

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New Issue of ‘Focus on Tax Strategies and Developments’


By , , , , , , and on May 12, 2016
Posted In IRS Audits, IRS Guidance, Uncategorized

We recently released the May 2016 issue of “Focus on Tax Strategies and Developments,” which can be viewed in its entirety here or through the links below. The issue includes four articles of interest to taxpayers: Proposed Debt-Equity Regulations Have Dramatic Implications for Corporate Tax Planning and Compliance By Thomas W. Giegerich and Michael J. Wilder On...

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