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Global Intangible Low-Taxed Income (“GILTI”)


Somewhat of a misnomer, the new provisions to tax the Global Intangible Low-Taxed Income (“GILTI”) of U.S. shareholders of a Controlled Foreign Corporation (“CFC”) will undoubtedly capture more than just traditional intangible income. For tax years beginning after December 31, 2017, the GILTI provisions generally require U.S. CFC shareholders to include in their currently taxable Subpart F income their share of the CFC’s deemed intangible income return for the tax year. Given the expanded CFC definition under the new law (possible CFC status anytime there is a U.S. shareholder of a foreign corporation anywhere in the group), the possibility for a GILTI inclusion or any other Subpart F inclusion should be closely evaluated.


Please see "New Income Inclusion for Global Intangible Low-Taxed Income (“GILTI”)" article for more information.


Elisa Fay


Partner-in-Charge Rödl National Tax

+1 404 525 2600

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