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Etiket 'global tax and accounting' (1)

Us & Uk Tax Services In London

GILTI is generally calculated as the net tested income of all CFCs, minus the 10% return on the QBAI of all CFCs with tested income. The proposed § 250 regulations issued in March 2019 have helpfully extended the 50% GILTI deduction to individuals electing under § 962 to be taxed like corporations on their GILTI. However, in these circumstances, the § 962 election would not provide a higher value for sale. Furthermore, the election is only available to 10% US shareholders who are deemed...

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