April 7, 2021
Ecovis Global published an article from International Tax Co-Leader Mark Chaves, about the GILTI high tax election in the United States.
Ecovis Global
By Mark Chaves, Co-Leader, International Tax
Excerpt:
Under this election, a US shareholder of a CFC will not be required to include GILTI income on his/her/its US income tax return if the CFC’s effective tax rate, as determined under US income tax principles, exceeds 18.9%. Once this threshold is met, a US shareholder can elect to exclude a tested unit’s (defined below) income entirely in determining the GILTI amount.
