US tax reform set to increase number of CFCs and transparency risk

The US tax reform introduces changes to Subpart F stock attribution rules that are expected to result in the formation of many new controlled foreign corporations. However, the amendments leave room for interpretation with tax professionals mooting whether the new repatriation and GILTI taxes could also be triggered.
Unlock this article.
The content you are trying to view is exclusive to our subscribers.
To unlock this article: