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: 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

Direct Tax

Tax lawyers make up nearly half of Withers’ promotions round

All the tax partners elevated across the UK, US and Singapore were private client specialists, continuing a market trend of intense investment and competition

Tom Baker, July 01 2026

Transfer Pricing

Exclusive: Dutch TP software provider Reptune names new CEO

Rolf van de Velde, dubbed ‘an expert chosen by experts’, is tasked with scaling Reptune’s self-service compliance offering

Sam Sholli, June 30 2026

Direct Tax

Perkins Coie and Ashurst merger closes to form $2.8bn firm

The newly combined firm brings together more than 3,500 practitioners across 52 offices, with flagship hubs in Seattle, London, Sydney and New York.

Noemi Distefano, June 29 2026

Direct Tax

‘Large, complex, difficult’: A&M Tax leaders reveal India expansion challenges

Building a transparent culture, prioritising internal promotions and being different from the big four are all key features of A&M Tax’s ambitious plans for India

Sam Sholli, June 29 2026

Indirect Tax