March 2018 JD Supra

The Tax Cuts and Jobs Act (TCJA) introduced several complex, hard to understand international tax provisions to the Internal Revenue Code.  One of them is the tax on Global Intangible Low-Taxed Income (GILTI).  Beginning with January 2018, a U.S. shareholder of any Controlled Foreign Corporation (CFC) is required to include its pro rata share of GILTI in its annual reportable Gross Income.  The GILTI tax is imposed on