Controlled Foreign Corporations

IRS issues proposed regulations on global intangible low-taxed income for U.S. shareholders

IRS issues proposed regulations on global intangible low-taxed income for U.S. shareholders

Under the TCJA, a U.S. person that owns at least 10 percent of the value or voting rights in one or more CFCs will be required to include its global intangible low-taxed income as currently taxable income, regardless of whether any amount is distributed to the shareholder. A U.S. person includes U.S. individuals, domestic corporations, partnerships, trusts and estates.