Law360 (October 16, 2019, 3:56 PM EDT) -- Major federal tax changes adopted in 2017 included adoption of a tax on global intangible low-taxed income, or GILTI, generated from investments in controlled foreign corporations, or CFCs, and an export tax subsidy allowing a tax deduction for a part of a taxpayer's foreign-derived intangible income, or FDII. Corporate shareholders were then granted a deduction for part of their new GILTI to lessen its impact.
Despite their "intangible" labels, these changes affect operating income from any source and can have a significant impact on taxpayers owning an interest in a CFC either directly or through a partnership or S corporation or...
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