For Sec. 962 and GILTI, Treasury said "Let people be corporations" and on March 4/19 "It came to be"

Summary: Dr. Karen Alpert - <a href="http://www.FixTheTaxTreaty.org">http://www.FixTheTaxTreaty.org</a><br><br>John Richardson - <a href="http://www.CitizenshipSolutions.ca">http://www.CitizenshipSolutions.ca</a><br><br>Monte Silver - <a href="http://www.silvercolaw.com">http://www.silvercolaw.com</a><br><br>The consequences of the December 2017 U.S. Tax Reform included sweeping changes to U.S. tax treatment of CFCs (Controlled Foreign Corporations). These changed included the Sec. 965 transition tax and Sec. 951A GILTI. Individual shareholders of CFCs were treated far more harshly than corporate shareholders of CFCs.<br><br>In relation to the GILTI provisions Internal Revenue Code Sec. 250 allowed corporate shareholders a 50% deduction of their GILTI income before taxation was imposed. Individuals shareholders were NOT afforded the same 50% statutory deduction.<br><br>On March 4, 2019 Treasury announced that it would interpret Sec. 962 to allow those individual shareholders, who made the Section 962 election (as part of that election) to have the same 50% deduction of GILTI income that was allowed to corporations.<br><br>This video continues the video series in which John Richardson interviews Dr. Karen Alpert and U.S. tax lawyer Monte Silver on the impact of these tax changes on individuals - particularly on Americans abroad.