Tag Archives: Subpart F

Sales of CFCs Got Harder?

▪ Written by

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.

State of Uncertainty: GILTI Considerations for Individuals

▪ Written by and
Our International Tax Group explores the hidden terrain for individuals found in the new tax on global intangible low-taxed income (GILTI). The Section 250 deduction The renewed importance of Section 962 Beware of the C-corp. lobster pot Read the full advisory here. [...]Read more

International Tax Reform Is Here

▪ Written by and
Our International Tax Group reveals how savvy and flexible taxpayers can optimize their tax position in the new landscape created by the Tax Cuts and Jobs Act. New territorial system and mandatory repatriation Anti-base erosion measures Changes to Subpart F and other provisions Click here to read the full advisory. [...]Read more