Under the Subpart F regime, income subject to the regime is initially defined by what it includes, while under the GILTI regime, income subject to the regime is initially defined by what it excludes. This article discusses the application of these different approaches in the context of nonliquidating distributions from a controlled foreign corporation to a U.S. shareholder.
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February 2021 - The Tax Adviser
- Magazine
- February 2021
FOREIGN INCOME & TAXPAYERS
employee benefits & pensions
Sec. 457 government plan distributions compared to 401(k) distributions
This article examines the different contribution and distribution rules for the two types of plans.
TAX CLINIC
corporations & shareholders
DEPRECIATION
expenses & deductions
FOREIGN INCOME & TAXPAYERS
INTEREST INCOME & EXPENSE
partners & partnerships
S CORPORATIONS
STATE & LOCAL TAXES
COLUMNS
TAX PRACTICE RESPONSIBILITIES
CAMPUS TO CLIENTS
PRACTICE MANAGEMENT
2024 tax software survey
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