GILTI: US Controlled Foreign Corporations Come Under Fire

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Recent progression with the US transition tax under the Tax Cuts & Jobs Act 2017 on deferred overseas income and the new Global Intangible Low Taxed Income tax ruling will impose several important changes to the standards administering controlled foreign companies.

Legal specialists have commented how the laws will drastically influence the tax assessment of US residents who are closely involved with foreign organisations and in some cases will oblige the re-evaluation of a lot of current structures as we know them today, including succession planning structures set up by non-US residents for US beneficiaries.