'Partial' GILTI tax victory seen in latest Treasury regs regarding 'high-tax exceptions' for foreign corporations

The U.S. Treasury Department on Monday issued what it said was a "final regulation" addressing how income earned by foreign corporations that has already been subject to a high rate of foreign tax may declared, in order to "allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their Global Intangible Low Taxed Income (GILTI) computation on an elective basis".

  • Tax

Monte Silver: TCJA still a major problem, but some progress seen in recent GILTI revisions

President Trump's Tax Cuts and Jobs Act 2017, which took effect on Jan. 1, 2018, has been a huge issue for many Americans who own as little as 10% of a small overseas business. Caught up in a clumsy legislative effort aimed at such large multi-national American companies as Google and Apple, these small business owners are, as has been frequently reported by this media organization and others, being forced to pay a 17.5% transition tax on income from their small business entities that dates back as far as the 1980s. 

  • Tax

Treasury official reported to hint at plans to address GILTI concerns

The U.S. Department of the Treasury is planning to address a much-criticised aspect of the Tax Cuts and Jobs Act that currently would see individual American taxpayers facing potentially higher taxes on their overseas income, a report published on Thursday said, citing a Treasury official. 

  • Tax
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Opinion

'After a 20-year relationship, I'm giving up on Mexico'

'After a 20-year relationship, I'm giving up on Mexico'

A retired dentist from Fort Worth, Texas, Kenneth Karger fell in love with Mexico two decades ago, as did his family. Here, in a first-person article addressed in part to...

Jul-30-2020