The Chamberlain Hrdlicka Business and International Tax Blog provides updates, developments, and insights on business and international tax.
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Sorting Out the Parallel Universes of Subpart F and GILTI Income Inclusions: The Unintended Collision With Respect to Deemed Sale of Controlled Foreign Corporation Stock
By Jerald David August
The Tax Cuts and Jobs Act of 2017, P.L. 115-87 (TCJA),  enacted into law on December 22, 2017, introduced numerous reforms to international taxation which changes have already had a profound impact on tax planning for multinational business enterprises (MNEs) as well as domestic businesses engaged in foreign business ventures or investments. The most significant reform enacted ...