GLOBAL INTANGIBLE LOW-TAXED INCOME INCLUSION (“GILTI”)

The Tax Cuts and Jobs Act of 2017 (“TCJA”) brought forth a sea of changes in tax law and one of the most consequential of these changes is the new rules under Code Sec. 951A, Global Intangible Low-Taxed Income Inclusion (“GILTI”). 

Moving to a territorial tax system for corporations, as the world has been using for many years, proved difficult for the United States government since many in the government were concerned about the abuse by domestic corporations of such system. The solution for these concerns was GILTI, an “anti-abuse” mechanism through which 10% U.S. shareholders of controlled foreign corporations (CFCs) are required to include in their gross income their share of the CFC’s inclusion amount for the year. 

What is the inclusion amount? What information is needed to arrive at such amount? Am I compliant with the new GILTI regime? These are all very important questions that require the advice of a trusted CPA firm specializing in international tax issues. At Kaufman Accounting PC we specialize in helping clients navigate through the maze of complex tax laws to help them concentrate on running their business.