If a C Corp purchased $500,000 of inventory from a CFC would the $500,000 received by the CFC be considered US effectively connected income, and therefore not subject to GILTI?
Hi, What if a US individual owns a CFC 100 percent and takes dividends, is that included in the GILTI tax? For example, if the CFC does 300K in profits and 200K is taken out as dividends by the US individual which would go on the 1040 as dividend income, is the GILTI Tax calcualted on 300k or 100k?
If a C Corp purchased $500,000 of inventory from a CFC would the $500,000 received by the CFC be considered US effectively connected income, and therefore not subject to GILTI?
what's the diff between in Subpart F and GILTI?
Hi, What if a US individual owns a CFC 100 percent and takes dividends, is that included in the GILTI tax? For example, if the CFC does 300K in profits and 200K is taken out as dividends by the US individual which would go on the 1040 as dividend income, is the GILTI Tax calcualted on 300k or 100k?
I don't believe you would take out the dividend. Your GILTI tax would be calculated on the $300.