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A #GILTI Carveout For INDIVIDUAL CFC Shareholders Of Certain Virgin Islands Corps
Introduction and purpose: The Big Beautiful Bill (โBBBโ) Contains many surprises. Yesterday, I wrote a first post about a section of the BBB that addressed the application of the GILTI rules. GILTI, Americans Abroad And SEC. 111110 Of The Big Beautiful Bill: The Good, The Bad And Theย Ugly That post was largely based on an interesting expose in the Washington Post. This called attention to theโฆ
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GILTI, Americans Abroad And SEC. 111110 Of The Big Beautiful Bill: The Good, The Bad And The Ugly
Introduction and purpose GILTI โ found in IRC 951A โ is one of the most problematic manifestations of U.S. citizenship taxation. It has caused huge compliance problems and costs for Americans abroad. The costs are composed of (1) the compliance costs of Form 5471 and (2) the possibility of the payment of U.S. taxes. All businesses understand that taxes are a cost of running a business. GILTI hasโฆ
