THE TRANSATLANTIC MAGAZINE
The past few weeks have seen big wins in the campaign against GILTI taxes and their impact on overseas Americans who run small businesses. Monte Silver, a US Tax Attorney and leading advocate in the GILTI case, explained earlier this month how relief had been won for overseas Americans on the GILTI regulations. Now, Mr Silver has outlined that the final regulations published the IRS go much further in offering complete exemption to some businesses.
In a blog posted on his website, Mr Silver wrote that "Yesterday, Treasury issues final regulations that exclude from the GILTI regime all corporate income which is taxed at least 18.9% in the country of residence. In essence it means this: if your company is subject to corporate tax of 18.9% on all its income, then none of that income is subject to GILTI. And since you have no GILTI income, YOU DO NOT HAVE TO COMPLY WITH GILTI AT ALL!!!!!"
NB: You can see the latest corporation tax rates for the UK at www.gov.uk/government/publications/rates-and-allowances-corporation-tax/rates-and-allowances-corporation-tax
To answer any questions about the new regulations, Mr Silver is hosting a free to attend webinar on Thursday July 30. There are two sessions of the webinar, one at a time suited to those in Asia and Europe, and another suited to those in America and Europe. Details on the timings and how to register are below:
Asia/Europe – Japan/Seoul 7pm, Perth/Beijing 6pm, Israel 1pm, France/Germany 12 noon, London 11 am
Americans/Europe - PST 9am, EST 12pm, London 5pm, France/Germany 6pm, Israel 7pm