You may be subject to GILTI if: U.S. Shareholder – United States Person (citizens, residents, domestic entities) owning at least 10%, directly or indirectly, of the foreign corporation’s voting stock or value (Prior toTCJA only consideration was voting stock). Controlled Foreign Corporation (CFC) – any foreign corporation of which more than 50% of the vote or value is owned by U.S. shareholders on any day during a given year. […]
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