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A Deep Dive into G.I.L.T.I. Guidance

Volume 5 No 10    |    Read Article

By Rusudan Shervashidze, Stanley C. Ruchelman, and Elizabeth V. Zanet

The I.R.S. has published proposed regulations on the global intangible low-taxed income ("G.I.L.T.I.") regime, which is applicable to those controlled foreign corporations that manage to operate globally without generating effectively connected income taxable to the foreign corporation or Subpart F Income taxable to its U.S. Shareholders. In a detailed article, Rusudan Shervashidze, Elizabeth V. Zanet, and Stanley C. Ruchelman examine the proposed regulations and all their complexity.   See more →