Just as a bit of extra context to anyone tuning in to this, Biden is considering potentially increasing the rate of tax on GILTI to 21% (that is, removing the 50% deduction); applying that rate from the first cent (rather than on the portion of income that exceeds a notional 10% rate of return); and applying the GILTI high-tax exclusion on a country-by-country basis (currently applicable in cases where foreign tax on covered income amounts to 18.9% or more). Not sure if all that will be adopted but it's what he said in the run-up to the election. He has also discussed raising the rate of CIT to 28 percent.
If both citizens combined own more than 50% of the foreign corp and individually own more than 10%, that would trigger a 5471 filing requirement that would be included in their 1040 return, which includes the GILTI calculation. Anyone feel free to correct me if I'm wrong. I'm also relatively new to int'l tax.
This is the best video on GILTI intro for sure thank you!
Thank you, i'm belgian student of International Fiscal Law, i've exam on monday, with BEAT, GILTI FDII. (US Tax reform)
Subbed and liked! Great content on US corporate taxes and crisp presentations! Thank YOU Michael!!
Just as a bit of extra context to anyone tuning in to this, Biden is considering potentially increasing the rate of tax on GILTI to 21% (that is, removing the 50% deduction); applying that rate from the first cent (rather than on the portion of income that exceeds a notional 10% rate of return); and applying the GILTI high-tax exclusion on a country-by-country basis (currently applicable in cases where foreign tax on covered income amounts to 18.9% or more). Not sure if all that will be adopted but it's what he said in the run-up to the election.
He has also discussed raising the rate of CIT to 28 percent.
Thank you for adding this! It will be interesting to see if the Democrats are able to successfully enact tax reform.
Thanks!
This is exactly what I was looking for. Thanks.
Thanks! You really explain it well.
Glad you think so!
This is a really clear explanation. Thank you.
Thanks for this!
No problem!
CFC Sales to a US Company (Same shareholders as the CFC) considered Subpart F income since it is Sales outside the CFC's country of Incorporation?
What if there is no parent US company and the foreign company is just owned by 2 or more US citizens?
If both citizens combined own more than 50% of the foreign corp and individually own more than 10%, that would trigger a 5471 filing requirement that would be included in their 1040 return, which includes the GILTI calculation. Anyone feel free to correct me if I'm wrong. I'm also relatively new to int'l tax.
the GILTI deduction is a special deduction right so if I'm in a taxable loss I don't get to benefit from the sec 250 deduction correct?
Where does the interest expense go in the formula?
Can you add video for FDII?