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

Download the special report

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. GILTI is an additional category of income that is taxed on a current basis to U.S. shareholders of controlled foreign corporations, even though the income is not distributed.

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.

Checkpoint International Tax Research

The international tax landscape is ever-evolving. With major legislative movements like BEPS, FATCA, and CRS, there are new layers of tax transparency as tax authorities are joining forces to standardize regulations across jurisdictions. What used to take years to become a law is now taking a fraction of the time. You need to keep up, and you need to keep up in every jurisdiction where your company or clients operate.

In addition, there is greater public awareness about multinational tax practices — and growing cynicism as to whether companies are paying their "fair share."

Provide your company with the versatility to adapt to this changing environment by leveraging the purpose-built international tools and resources from Thomson Reuters Checkpoint.

Learn more