GILTI - Global Intangible Low-Tax Income EXPLAINED: An intro

Attention Global Entrepreneurs and Investors! Is the IRS dragging you down? Text “Wealth” to 818-293-4857. Anthony's firm, Parent & Parent LLP can help end your tax anxiety and frustration right now! We do it all so you can focus on better things. 20 successful years experience in tax planning, tax resolution (including audits!), bookkeeping, asset protection, and offshore disclosures/FBAR help. Everything you need under one roof. Thousands helped!
More on what GILTI is: www.irsmedic.com/blog/2018/08...
How to avoid GILTI: www.irsmedic.com/blog/2018/12...
What is GILTI really?
We will be getting into the specifics of what GILTI is, but first, we need to understand what its purpose was as that will help us figure out situations in which we should expect to see GILTI liabilities pop up.
In 1962 Subpart F was passed to treat passive income overseas harshly. Subpart F is a vile nasty piece of work. But I guess Congress really liked it. Someone then got the idea that if Subpart F could be so effective in ruining most offshore tax planning, well then could we create some sort of taxing regime to hammer active income earned overseas?
The answer is yes and GILTI is its name. The purpose of GILTI is to hammer active income of foreign businesses that are controlled by US shareholders. GILTI can hammer them so hard, that for some people, having their income taxed as Subpart F could even be better than GILTI!
Oh and by the way, Tax Reform also expanded the definition of what it means for a shareholder to be subject to not just controlled foreign corporation rules that is CFC rules in addition to GILTI regime.
Be sure to subscribe as these are these the topics we will be covering in future videos.
How to avoid GILTI
How to calculate GILTI
GILTI vs Subpart F
GILTI regualtions
GILTI v transition tax
GILTI & NIIT
GILTI & BEAT
GILTI & Intellectual property
GILTI & Tangible property
GILTI and Section 250 deductions
GILTI and foreign partnerships
GILTI does not just affect huge corporations overseas, but small and medium sized businesses, and it can even affect someone who is self-employed. Now for some people with income earned abroad, GILTI won’t affect them all that much. But, it could take some real meaningful research and analysis to properly answer that question. For our larger clients, the cost may not be all that noticeable, but I can tell you that for our clients who are working hard to create something for themselves, this amount of research is pushing many beyond their breaking point, forcing them to make a decision they wish they didn’t have to. Just getting a GILTI analysis can cost more than what a taxpayer’s tax bill is.
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How to mitigate GILTI: www.irsmedic.com/blog/2018/12...
How to

[@donttread5414]

Im a dual US/CA citizen living in Canada and cannot grow my business or form a corporation because of CFC , SUBPART F and GILTI. Im forced to take a large salary as a sole-prop, take legal risks of being sued and pay an unnecessary amount of taxes instead of forming and keeping it in a Canadian corporation and investing in my community. I also cant properly invest for retirement because of PFIC's. My Canadian TFSA (Roth IRA) is also taxed by the IRS. Im absolutely disgusted the US treats its citizens this way.

[@irsmedic]

It's inhumane, isn't it? This is financial terror plain and simple. This is what happens when your tax code is not so much about revenue, but wildly misguided social engineering. Taxes should raise revenue to pay for essential functions of the government. Our tax code should not be used as a weapon to punish Americans who don't live their life the way those creepy Washington creatures think they should.
Passive-aggressive tyranny is still tyranny.
Be sure to support the effort to curtail at least some of this nonsense. TFFAA is a winner! be sure to check out this update in case you haven't already. We can actually win this thing! www.irsmedic.com/blog/2018/12/ttfi-bill-is-here.html

[@laobanK]

I would love it if you would address GILTI with regard to foreign partnerships. I had read that these as well as sole proprietorships are considered 'disregarded entities' and not subject to either Transition OR GILTI.

[@senseijoe8.292]

Some rumors have spread that an idea was created that replaces the idea to protest in front of the US embassies. Because Americans abroad are scared to protest in front of US embassies, why not wear a patch of the star of David with the American flag on it with the words "US Tax Slave"on it. This may gain a lot of attention.

[@funny1048youtube]

can gilti tax effect me if I invest in international stocks on vanguard

[@jakefreeman8075]

Yes they will make your investment go worthless. Sell as soon as possible.

[@mrashfaq2806]

Hello sir

[@gioiamiafumagalli184]

And then you wonder why so many U.S citizens are renouncing their citizenship...

[@hemantparakh8995]

I WOULD LIKE TO PAY ONE HUNDRED AND THIRTY FIVE DOLLARS AS AN INVESTMENT TO FETCH GILTI INCOME SO KINDLY ADD ME TO THE GILTI INCOME SCHEMES

[@dianawolf894]

GILTI