The GILTI Era for US Taxpayers
If you are a US person and own 10 percent or more stock in a Controlled Foreign Corporation (CFC), then you need to know about GILTI, or Global Intangible Low-Tax Income. This recent regulation requires that all your share of taxable income from these Foreign Companies be reported to the IRS and included as taxable income on your personal US Tax return. U.S. shareholders previously did not have to worry about the inclusion of their operating corporate profits on their individual U.S. tax return… But those days are gone. The Tax Cuts and Jobs Act (TCJA) of 2017, ushered in a new era in taxations for US taxpayers, the GILTI era. Now, a separate calculation must be done for each Controlled Foreign Company that you are a US shareholder in. Then, all these GILTI calculations are aggregated and applied to your US tax return. To make it worse – as an individual U.S. shareholder, you could be subject to a higher tax rate than the foreign companies themselves. Our t...