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U S. Final Regulations Under Gilti

The story is a bit different if the §962 election was made to reduce tax payable on GILTI. The cost of the election is that the shareholder only gets to treat an amount equal to the actual US tax paid as previously taxed, so most of the dividend will be taxable. This may not make much of a difference, however, as any tax paid where the shareholder lives will be available as a credit to offset US tax on the dividend. A domestic corporation that is a US Shareholder in a CFC is deemed to have...

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