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2021-02-28 21:42:34
The Treasury Department and the IRS request comments on these proposed rules. Internal Revenue Code Section 962 provides an election for individual U.S. shareholders so that their Subpart F income including GILTI is subject to federal income tax at the corporate tax rate of 21% rather than...
2021-02-24 21:46:51
person, and makes any U.S. beneficiaries of such a trust taxable as the deemed owners. If a foreign trust has a U.S. owner or beneficiary, U.S. tax reporting will be required. Transfers to, distributions from and annual income and expenses of foreign trusts must be reported on Forms 3520 and 3520-A...
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