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wiki:contents:us_tax:cfcs [2018/11/30 13:15] – [Numerical Examples] karen | wiki:contents:us_tax:cfcs [2018/11/30 13:32] – [GILTI] karen |
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====== GILTI ====== | ====== GILTI ====== |
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This section serves as a technical appendix to the blog post Explaining GILTI - Measurement [insert link when published]. | This section serves as a technical appendix to the blog post [[http://fixthetaxtreaty.org/2018/11/30/explaining-gilti-measurement/|Explaining GILTI - Measurement]]. |
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GILTI is found in [[https://www.law.cornell.edu/uscode/text/26/951A|§951A]] of the Internal Revenue Code. Note that the description below is general in nature. It ignores many of the problems that occur when a US taxpayer owns multiple CFCs or has to allocate expenses between tested income and income taxed under other provisions. | GILTI is found in [[https://www.law.cornell.edu/uscode/text/26/951A|§951A]] of the Internal Revenue Code. Note that the description below is general in nature. It ignores many of the problems that occur when a US taxpayer owns multiple CFCs or has to allocate expenses between tested income and income taxed under other provisions. |