GILTI as Charged: How to Structure Successful U.S. Offshore Business Activities

Sullivan Tax Briefing (4:00 – 5:45 p.m.)
Sullivan & Worcester Conference Center, Boston, MA
November 14, 2018

The 2017 Tax Act introduced a ton of changes to the Internal Revenue Code, but arguably none bigger than the introduction of Global Intangible Low-Taxed Income (GILTI), which has turned completely upside down the US taxation of offshore business activities conducted through controlled foreign corporations (CFCs).

Doug Stransky provided attendees with the good, the bad, and the ugly regarding the GILTI rules, and examined various strategies on how best to manage its curious and quirky provisions. Topics covered included the following:

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