US Cross-Border Tax Blog

Published by W.L. Dueck LLP

Posts filed under ‘GILTI’

AndersenTax

IRS Regulations Clarify 250A Deduction for Individual Owners of Non-US Corporations Subject to GILTI

Last fall, we wrote about the US’s Global Intangible Low Taxed Income (“GILTI”) and its’ adverse tax impact on US persons that own non-US corporations.   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.  Our original blog entry can be found here:   https://wldtax.com/global-intangible-low-taxed-income-gilti/ One of the concerns tax practitioners have regarding GILTI is its application to… Read More

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