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Special report: Should Companies Plan Into Subpart F Following U.S. Tax Reform?

Overpayments Webinar

Following the enactment of the US Tax Cuts and Jobs Act (TCJA), US multinational companies (MNCs) are now faced with a new anti-deferral provision in the form of the global intangible low-taxed income (GILTI) inclusion.

Depending on the facts, it may be advantageous for a corporate US shareholder to have subpart F income, as opposed to GILTI, even with the 50% deduction allowed under section 250.

Download this special report to learn more about how MNCs are going back to the drawing board and modeling out their tax liability for GILTI and Subpart F.

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