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 new tax law’s global intangible low-taxed income (GILTI) rules for controlled foreign corporations (CFCs). GILTI “applies harshly to non-C cor­poration US shareholders of CFCs,” the authors wrote, and although “measures are available to reduce or partially defer the tax … careful consideration should be given to the taxpayer’s particular circumstances.”