MNEs get easy ride under US repatriation and GILTI regimes as US expats pick up the bill

May 22 2018

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.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

A taxing week: HMRC’s GfC13 puts tax advisers in an unwinnable situation

The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations

Tom Baker, December 12 2025

Direct Tax

Taylor Wessing in merger talks with US firm Winston & Strawn

Taylor Wessing, whose most recent UK revenues were at £283.7m, would become part of a £1.23bn firm post combination

Tom Baker, December 12 2025

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

This week in tax: China adds to growing list of US pillar two carve-out dissenters

China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap

Sam Sholli, December 12 2025

Direct Tax