The Tax Cuts and Jobs Act (TCJA) added a new income inclusion under Section 951A for global intangible low-taxed income (GILTI) that introduces the possibility for additional U.S. taxation of worldwide income. The income inclusion is a complex calculation and may require a detailed analysis of tangible fixed assets to determine the amount of qualified business asset investment (QBAI) a taxpayer can benefit from.
This webinar will focus on the significant aspects of the GILTI income inclusion and additional global tax-planning considerations for taxpayers.
At the conclusion of this session, participants will be able to:
- Understand the components and computation of the GILTI income inclusion on controlled foreign corporation income.
- Understand the calculation of U.S. tax on GILTI income and the corresponding GILTI foreign tax credit.
- Assess how to limit GILTI income as part of an overall global tax-planning strategy.
- Consider advantageous future tax-structuring alternatives for U.S.-owned foreign corporations.
Presenters:
- Steve Schnepel, international tax partner
- Randall Janiczek, international tax partner
- Robert Malmstadt, international tax manager
