GILTI Rules Particularly Onerous For Non-C Corporation CFC Shareholders



Sandra McGill, Gary Karch, Kevin Feeley, Susan O’Banion and Justin Crouse wrote this bylined article on the global intangible low-taxed income (GILTI) rule in the new tax law. The authors wrote that the rule “applies harshly to non-C corporation US shareholders of CFCs [controlled foreign corporations]” and urged that “careful consideration should be given to the taxpayer’s particular circumstances and overall tax position in determining what steps make sense.”