U.S. shareholders of foreign corporations have a new pass-through income category to contend with: GILTI. Except for capital-intensive companies, this has the effect of making foreign operating income immediately taxable to U.S. shareholders. This session explores the new rules. What is GILTI? How will it affect U.S. shareholders? What countermeasures are available?
*Identify Section 951A rules and filing requirements
*Determine whether foreign income is susceptible to GILTI requirements
*U.S. shareholders of foreign corporations