US Cross-Border Tax Blog

Published by W.L. Dueck LLP

Posts filed under ‘GILTI’

AndersenTax

Global Intangible Low-Taxed Income (“GILTI”)

The December 2017 US tax reform included a provision to subject to US tax the earnings of intellectual property owned by US investors outside the US. Known by the unfortunate name of GILTI, its application is much broader than just Apple, Amazon, Google and the like. GILTI impacts US persons resident in Canada who own Canadian and other non-US corporations. Without effective tax planning, combined US and Canadian tax rates approaching 85% could occur as early as 2018.  GILTI applies… Read More