Deep Dives16 min read
GILTI for U.S. Founders Abroad: A 3-Step Playbook
You need to make three decisions, in order. First, whether you are in scope. Second, which inputs create a current inclusion. Third, whether default treatment, a Section 962 election, or a structuring conversation is the right next move. If the global intangible low-taxed income, or GILTI, rules apply, your goal is a clear scope decision, a supportable exposure model, and a defined point where you escalate.
gilticfcus international tax+2 more
Read →