#gilti

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A #GILTI Carveout For INDIVIDUAL CFC Shareholders Of Certain Virgin Islands Corps

Introduction and purpose: The Big Beautiful Bill (“BBB”) Contains many surprises. Yesterday, I wrote a first post about a section of the BBB that addressed the application of the GILTI rules. GILTI, Americans Abroad And SEC. 111110 Of The Big Beautiful Bill: The Good, The Bad And The Ugly That post was largely based on an interesting expose in the Washington Post. This called attention to the…

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GILTI, Americans Abroad And SEC. 111110 Of The Big Beautiful Bill: The Good, The Bad And The Ugly

Introduction and purpose GILTI – found in IRC 951A – is one of the most problematic manifestations of U.S. citizenship taxation. It has caused huge compliance problems and costs for Americans abroad. The costs are composed of (1) the compliance costs of Form 5471 and (2) the possibility of the payment of U.S. taxes. All businesses understand that taxes are a cost of running a business. GILTI has…

GILTI, Americans Abroad And SEC. 111110 Of The Big Beautiful Bill: The Good, The Bad And The Ugly

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Monte Silver's Lawsuit Opposing The Procedural Aspect of #GILTI Regs Lives On

In summary – Monte Silver’s lawsuit against GILTI lives on! On April 19, 2024 the U.S. Court Of Appeals released a decision which included: Plaintiffs had objected before the district court that the Anti-Injunction Act did not apply in light of South Carolina v. Regan, 465 U.S. 367 (1984), because they had no other way to litigate their claims. The defendants argued that the Act barred the suit…

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Part 45 - "Some" examples where the U.S. creates unrealized "foreign income" before a realization event in the source country

Let There Be Income And There Was Income! The United States has an increasing propensity to create “deemed income” in circumstances where the taxpayer has received no income to pay the tax. In some cases the “deemed income” created is “foreign source” income. In other cases it is purely domestic source. When the “deemed income” is “foreign source” income over which the other country has primary…

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Part 44 - The Moore's, Unrealized Income And The U.S. Extraterritorial Tax Regime

Exporting U.S. taxes, forms and penalties to the residents of other countries "The Little Red Transition Tax Book" – Everything you need to know about the 965bmandatory repatriation tax but didn't know to ask. A horrific abuse of #Americansabroad in a @citizenshiptax and #FATCA world! https://t.co/j7v1Asreek — U.S. Transition Tax – Subpart F and #GILTI (@USTransitionTax) June 26, 2023 In the…

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Part 41: The Six Faces Of The 965 Transition Tax - The Ugliest Face Applies To Americans Abroad

Part I: Introduction – What Is The Transition Tax? "The Little Red Transition Tax Book" – Everything you need to know about the 965bmandatory repatriation tax but didn't know to ask. A horrific abuse of #Americansabroad in a @citizenshiptax and #FATCA world! https://t.co/j7v1Asreek — U.S. Transition Tax – Subpart F and #GILTI (@USTransitionTax) June 26, 2023 “Tell me who you are. Then I’ll tell…

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Part 40 - The Moore Appeal: Unrealized Income And Attacking The "Wealth Of OTHER Nations"

Introduction The Moore’s are U.S. residents who happen to be the U.S. shareholders of a CFC (“Controlled Foreign Corporation”). In basic terms, the Moore’s appeal is based on the fact that (1) although the Moore’s received no distribution from the CFC, they (2) were deemed to have received a distribution and required to treat the “deemed distribution” as U.S. taxable income. In other words, they…

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Global Intangible Low-Taxed Income and Canadian Corporations

Let’s simplify the GILTI for you. If you need a more detailed but simplified understanding of GILTI and how it affects the U.S. shareholders of Canadian corporations, read here