A Strong Dollar and Section 986(c): GILTI Problems Persist Despite Expense Allocation Changes
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A Strong Dollar and Section 986(c): GILTI Problems Persist Despite Expense Allocation Changes
Eric M. Lopata examines a common fact pattern that can cause taxpayers to pay global intangible low-taxed income tax on their foreign earnings, even though this residual GILTI tax is not reflective of the local operations or in-country tax paid by a controlled foreign corporation.
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