GILTI High Tax Kick-Out Election — Kicked Out by Dems!

On February 12, Senate Finance Committee Ranking Member Ron Wyden, D-Ore., and Senator Sherrod Brown, D-Ohio, introduced legislation to prevent the Treasury Department from carving out an exception (commonly called the GILTI High Tax Kick-Out) for multinational companies to escape the so-called GILTI provisions of the Tax Cuts and Jobs Act (TCJA). The title of the … Continue reading GILTI High Tax Kick-Out Election — Kicked Out by Dems!

Americans Abroad: Taxpayer GILTI Victory Just Announced in Proposed Regulations!

The Internal Revenue Service (IRS) just issued proposed Regulations dealing with the “Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income (“GILTI”)”.  The proposed regulations mark a big win for Americans running their businesses through foreign corporations.  The regulations are scheduled to be published in the Federal Register tomorrow.  In part, they address the … Continue reading Americans Abroad: Taxpayer GILTI Victory Just Announced in Proposed Regulations!

Quicksand! US Owners of Foreign Corporations

It is usually very quick and easy to set up a foreign corporation - say, one in Belize or in the Cayman Islands.  What is not so easy is working one's way through the quagmire of required Internal Revenue Service (IRS) reporting and US  tax obligations simply because you are a US person owning shares … Continue reading Quicksand! US Owners of Foreign Corporations