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

Transfer Pricing

A taxing week: Why delegating document work to LLMs is riskier than you think

New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows

Marc Mokrab, July 10 2026

Direct Tax

PM-in-waiting Burnham unlikely to deviate from tax agent registration: experts

Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard

Sam Sholli, July 09 2026

Awards

ITR Europe Tax Awards 2026: shortlist announced

ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards

John Harrison, July 09 2026

Direct Tax

Charles Russell Speechlys enters US with private client splash

The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition

Sam Sholli, July 08 2026

Direct Tax

‘Multiple versions of truth’: EY leader on in-house tax data challenges

The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution

Sam Sholli, July 08 2026

Direct Tax

Burlington v HMRC and the interpretation of double taxation treaty anti-avoidance clauses

The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests

Matthew Greene, July 07 2026

Transfer Pricing

Person working on screen with financial graphs and overlaid network

Beyond the headlines: Are TP software providers challenging tax advisory hegemony?

Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players

Tom Baker, July 06 2026

Direct Tax

A taxing week: EY allegations suggest big four scandal at all levels

Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four

Sam Sholli, July 03 2026

Direct Tax

Hogan Lovells Cadwalader’s $3.6bn merger goes live

Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices

Noemi Distefano, July 02 2026

Direct Tax

Libyan tax disputes: choosing between settling and challenging

The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation

Salaheddin El Busefi , July 02 2026