TAX 9869 Lecture Notes - Lecture 20: W. M. Keck Observatory, Passive Income, Cayman Islands
Document Summary
Gr: a us owner of fc did not pay tax on earnings until the earnings/income was repatriated/ distributed as a dividend. Gilti: on an annual basis will require some level of inclusion of income of cfc. Subpart f must be computed before gilti. Kinda like a backstop// you have this deferral rule. Us person doesn"t pay tax on earnings earned of fc until brought back = deferral changed w/ Are categories of income and those categories even tho earned by cfc// if u are a. Ussh of that cfc then you need to pick up your subpart f income (that type of income earned by cfc is immed. taxed to ussh) Its the ussh on the last day of cfcs accounting period/year. Ex: might own it for whole year but sell it to you (both us persons) on last day of year then you would need to pick up income based on ratable share.
