GILTI – Global Intangible Law-Taxed Income

The latest U.S. tax reform legislation (Tax Cuts and Jobs Act of 2017 -TCJA) enacted new requirements for U.S. shareholders of Foreign Corporations. Under the Act, a U.S. person who owns at least 10% of the shares of one or more foreign controlled corporation is required to include its Global Intangible Low-Taxed Income (GILTI) as current taxable income, regardless of whether any amount is distributed to the shareholder.

Effective for the first tax year of a Controlled Foreign Corporation (“CFC”) beginning after December 31, 2017, each US taxpayer who is a “US shareholder” of a CFC will be subject to current US income taxation to the extent that the CFC is deemed to have GILTI income under the new Code §951A.

Calculating GILTI inclusion involves a multi-step with numerous data inputs. Our professionals can help you analyze the impact of GILTI on your tax obligations and craft a strategic plan that considers and accommodates its effects.