GILTI or maybe not……..

The United States has recently imposed the Global Intangible Low-Taxed Income tax (‘GILTI Tax”) on Controlled Foreign Corporations (‘CFCs’), i.e. non-US companies where a US company, partnership or person owns more than 50 percent of that non-US company. The GILTI Tax is primarily aimed at the likes of Google, Apple, Amazon etc. to try and […]

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