U.S. shareholders of CFCs may pay tax on the CFCs’ earnings even before actual distributions from the CFCs. A foreign corporation is a CFC if 50%+ stocks are owned by U.S. shareholders. The Tax Cuts and Jobs Act of 2017 added one-time transition tax and GILTI provisions. The Code and the Regulations provide various exceptions, exemptions, and elections to the taxes. The court cases and the Revenue Procedures confirm those escapes. Assess your situations, plan ahead, and avoid surprise. Choi & Partners help you:

  • Evaluating Subpart F including GILTI and other anti-deferral tax provisions
  • Maximizing Foreign tax credit
  • Repatriation planning including distribution of PTEP
  • Structuring foreign entities for better tax result
  • Planning for FDII deduction and IC-DISC incentive