Year-End Considerations for GILTI Planning

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US tax reform has brought about numerous changes over the past year, including the new Global Intangible Low Taxed Income (GILTI) tax. Join McDermott tax attorneys in our Miami office for a roundtable discussion focused important aspects of the recently released GILTI regulations.

We will focus on the following topics:

  • Expense apportionments to GILTI and foreign tax credit considerations
  • State tax consequences of GILTI
  • Evaluating the important aspects of the forthcoming proposed Treasury Regulations
  • Comparing the benefits and burdens of the structuring options available to shareholders, including:
    • Converting ownership to flow-through (rather than corporate) form
    • Converting GILTI to Subpart F income (situations where the latter is preferable)

For more information, please contact Maria Dubinets.

CLE Credit is pending. A uniform Certificate of Attendance will be made available to participants.

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