Subpart F income requires U.S. shareholders of controlled foreign corporations to report certain categories of foreign income — even when no distribution is made. This article explains how Subpart F ...
On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19) that will provide significant ...
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