Tag Archives: global intangible low-taxed income

Sales of CFCs Got Harder?

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Our Federal Tax Group gives a glimpse into the brave new world of selling foreign assets and stock in the wake of the Tax Cuts and Jobs Act.

  • Selling a U.S. sub versus selling a CFC
  • GILTI as a new option over Subpart F
  • Analyzing the options

Read the full advisory here.

GILTI Basis Adjustments

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Our Federal Tax Group explores how Treasury’s proposed regulations could have the global intangible low-taxed income (GILTI) regime operating in a way you might not expect.

Read the full advisory here.