Planning for IRC 951A - No reprieve for the GILTI
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| | | February 2019 | Planning for IRC 951A - No reprieve for the GILTI
Todd King, CPA, CA, CPA (Illinois), TEP, is Tax Practice Leader in Baker Tilly’s Dartmouth office
Martha MacRae, is Senior Manager, US Tax in Baker Tilly's Dartmouth office | | Our last article focused on the impact of IRC 965 (a.k.a. the repatriation tax or transition tax) on US citizens resident in Canada. IRC 965 was brutal for those impacted by it, forcing them to choose between retroactive double taxation on corporate earnings not yet distributed or accelerating Canadian personal tax due to early distribution of corporate earnings. While 2017 marked the passing of the transition tax, 2018 marked the beginning of an even more punitive regime: IRC 951A or the GILTI (Global Intangible Low-Taxed Income) regime. This article will provide an overview of the GILTI rules and their implications, as well as exploring planning options that should be considered by those subject to the rules. |
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Baker Tilly Canada periodically publishes U.S. Tax Alert for its clients and associates. It is designed to highlight and summarize the continually changing tax and business scene across Canada with respect to U.S. issues. While U.S. Tax Alert may suggest general planning ideas, we recommend professional advice always be sought before taking specific planning steps. |
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