As the third part in our “Confiscation Tax” webinar series, we covered the 2017 US tax reform’s GILTI provision. This webinar took place on Tuesday, February 19th at 12:00 London GMT.
The US’s Tax Cuts and Jobs Act (TCJA) of 2017 introduced a wide array of new and relatively complex rules to the American tax code. One of these is the tax provision on Global Intangible Low-Taxed Income (GILTI), which requires a US shareholder of any Controlled Foreign Corporation (CFC) to include its pro rata share of GILTI in its annual reportable Gross Income. This specific tax applies to the GILTI of 10% or greater US taxpayer shareholders of a CFC.
Some of the questions discussed during the webinar included:
- How does the IRS define Global Intangible Low-Taxed Income (GILTI)?
- Who does the GILTI provision apply to?
- What is GILTI intended to do?
- How is GILTI calculated?
- What are the main deductions that are related to GILTI?
- How does GILTI interact with the Foreign Derived Intangible Income (FDII), another new component of the US tax reform of 2017?
- In your opinion, how will GILTI impact the rest of the world outside of the US?
- And plenty more!
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John Richardson is a Toronto, Canada based lawyer. He provides advice and assistance for US citizens and Green card holders who do not reside in the United States. He specializes in US citizenship relinquishment, Green Card expatriation and assisting US persons with their compliance obligations. You can contact him on his website www.citizenshipsolutions.ca.
Dr. Karen Alpert,
University of Queensland Business School,
Dr. Karen Alpert lectures Finance at the University of Queensland Business School in Australia. Dr. Alpert’s qualifications include a PhD in Finance (University of Queensland), Masters in Tax (University of Southern California) and MBA (University of California, Berkeley). Her research explores the impact of taxation and government regulation on financial decision-making.