Year-End Considerations for GILTI Planning

Overview


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.