GILTI – be careful – international investments

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.
  • GILTI – Global Intangible Low Taxed Income (think it is mis-named as it implies INTANGIBLES… but it is way more than that)…..  if you have any international investments (not in United States) be sure you understand whether you are required to deal with this.
Translate »