As many readers are aware, the Tax Cuts and Jobs Act of 2017 (TCJA) dramatically changed the rules governing controlled foreign corporations (CFCs), including the introduction of a one-time transition tax on deferred foreign income, a new tax on global intangible low taxed income (GILTI) and other changes that expanded the scope of the CFC regime. However, one provision many advisors are still grappling with is the repeal of the limitation on downward attribution in former Internal Revenue
ARTICLE ACCESS REQUIRED
Please Log in if you are currently a Trust&Estates subscriber, or select DAYPASS for our new 24 hour access (nominal fee required).
If you are interested in unlimited article access for one year, please select Annual Subscription below.
0 comments
Hide comments