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GILTI High-Tax Exclusion: An Additional Planning Tool for Noncorporate US Shareholders

An individual or trust US shareholder of a controlled foreign corporation (CFC) faces harsh treatment under the global intangible low-taxed income (GILTI) regime. These tax implications have forced these taxpayers to pursue...more

International News: International Tax

Health Care Private Equity Investments in India - A flurry of recent private equity (PE) investments in the Indian health care sector demonstrates strong investor appetite and opportunities. India is one of the fastest...more

The New Participation Exemption: An Opportunity to Convert Ordinary Dividends into Qualified Dividends

The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign...more

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