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Guide to Global Intangible Low-Taxed Income (Section 951A)

U.S. shareholders of foreign corporations have a new pass-through income category to contend with: Global Intangible Low-Taxed Income (Section 951A). Except for capital-intensive companies, this has the effect of making foreign operating income immediately taxable to U.S. shareholders. This session explores the rules. What is Global Intangible Low-Taxed Income? How does it affect U.S. shareholders? What countermeasures are available?

Presenter: Phil Hodgen

Materials: Dropbox