Although the 2017 US Tax Cuts and Job Act (TCJA) aimed to cut taxes for all Americans, individual US shareholders of controlled foreign corporations (CFCs) living outside the US (expats) are being discriminated against under the repatriation and GILTI tax regimes. Monte Silver of Silver & Co in Israel explains why the likes of Google and Apple are getting a good deal.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Ireland’s Department of Finance reported increased income tax, VAT and corporation tax receipts from 2024; in other news, it’s understood that HSBC has agreed to pay the French treasury to settle a tax investigation
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two