Interlegal News Update - September 2018 - GILTI The New Category of US Taxable Income

The Tax Cut and Jobs Act (the “TCJA”), enacted on December 22, 2017, resulted in a sea change for U.S. tax law with respect to controlled foreign corporations (or CFCs). An impact of this for high net worth individuals who emigrate to the United States is a new category of income of CFCs which was created under TJCA, called “GILTI” or Global Intangible Low Tax Income. GILTI, and its potential to significantly increase the annual U.S. tax liability of these persons, is the focus of this article.