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

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

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

houston skyline 320x215

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
more across site & shared bottom lb ros

More from across our site

The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week
Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR
The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth
Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty
The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering
The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits
The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment
Gift this article