Navigating International Taxation: Maximizing GILTI and FDII for Global Enterprises
Revisions to the United States Tax Code in 2017 made vast alterations to the tax landscape for multinational businesses controlled by United States taxpayers. The "Global Intangible Low Taxed Income" (GILTI) provisions of §951A expanded anti-deferral efforts by the United States, creating immediate inclusions for most types of income earned by controlled foreign corporations. The blow of this inclusion was softened by the simultaneous creation of §250 which permits a 50% reduction in tax rate for domestic corporate United States shareholders. Non-corporate shareholders are taxed on GILTI at ordinary income rates as high as 37%. Also created by §250 is a 37.5% tax reduction for domestic corporations earning "Foreign Derived Intangible Income" (FDII), making the tax rate on this income 13.125%. However, decisions in how to structure multinational operations are not as simple as comparing these rates.
Join us for a program covering the basics both of GILTI and FDII and how they fit within the United States international tax regime. This webinar will also detail the decision-making considerations surrounding these inclusions, including whether a domestic or foreign incorporation is preferable. This analysis includes assorted factors such as foreign tax credit availability and potential source-country tax reduction for domestic corporations under income tax treaties.
Lambers, Inc. is a leader in review courses for the EA, AFSP, and CPA exams. Lambers also offers IRS Continuing Education for Tax Preparers and CPE for CPAs. Accounting and finance professionals around the world incorporate Lambers products into their training programs.
J.D., LL.M.
Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets. Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.
