Recommended Citation
Jeffery M. Kadet and David L. Koontz, Transitioning from GILTI to FDII? Foreign Branch Income Issues, 164 Tax Notes Fed. 57 (2019), https://digitalcommons.law.uw.edu/faculty-articles/513
Publication Title
Tax Notes Federal
Document Type
Article
Abstract
In this article, Kadet and Koontz explain the risks and benefits multinationals must consider in deciding whether to transition some operations conducted within a controlled foreign corporation (along with the associated income) into a domestic group member to achieve a structure that qualifies for foreign-derived intangible income.