News Analysis: Individuals and the Repatriation Tax - McDermott Will & Emery

News Analysis: Individuals and the Repatriation Tax

Overview


 

McDermott tax lawyers were cited as concluding that the deduction under the new tax law’s global intangible low-taxed income (GILTI) rule is prohibited for a section 962 election because the statute makes it available only to domestic C corporations, not even S corporations.