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Old January 13th, 2018, 04:13 AM   #31
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Quote:
Originally Posted by Supposn View Post
I'm among the proponents of a trade policy described within Wikipedia's “Import Certificates” article. The Import Certificate trade policy would have no problem with USA's new tax laws.
Respectfully, Supposn

Excerpted from:
https://www.nytimes.com/2018/01/08/b...e=sectionfront

Tax law may send factories and jobs abroad

Under the new law, income made by American companies’ overseas subsidiaries will face United States taxes that are half the rate applied to their domestic income, 10.5 percent compared with the new top corporate rate of 21 percent.
Strange that the Tax law is doing just the opposite.
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Old January 13th, 2018, 10:35 AM   #32
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Guy39 & Sabcat,
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Originally Posted by Supposn View Post
Guy39, the new tax regulations taxes corporate incomes from foreign sources at 10.5%. This further encourages corporations to invest abroad rather than in the USA, import products rather than produce them in the USA.

USA producers of products support USA's economy; producers of imported goods in aggregate effectively do nothing to support USA's economy.
Unlike the USA, foreign nations generally collect taxes from importers of goods into their nation. They do not tolerate foreign producers gaining advantages over their own domestic producers.
USA producers do, and foreign producers do not pay taxes and contribute to USA economy.

I'm among the proponents of the trade policy described by Wikipedia's “Import Certificates” article.
That policy is comparatively immune from any mischief.

Respectfully, Supposn
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Yup, it is an incentive to bring money back in from tax shelters. The horror. I think that there may be a time limit on it too, but im not sure.
Thanks from imaginethat
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Old January 13th, 2018, 11:23 AM   #33
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Originally Posted by Sabcat View Post
Yup, it is an incentive to bring money back in from tax shelters. The horror. I think that there may be a time limit on it too, but im not sure.
Here's the language from the tax bill:
Foreign intangible income: The act provides domestic C corporations (that are not regulated investment companies or REITs) with a reduced tax rate on “foreign-derived intangible income” (FDII) and “global intangible low-taxed income” (GILTI). FDII is the portion of a domestic corporation’s intangible income that is derived from serving foreign markets, using a formula in a new Sec. 250. GILTI would be defined in a new Sec. 951A.

The effective tax rate on FDII will be 13.125% in tax years beginning after 2017 and before 2026 and 16.406% after 2025. The effective tax rate on GILTI will be 10.5% in tax years beginning after 2017 and before 2026 and 13.125% after 2025.

Definition of U.S. shareholder: The act amended the ownership attribution rules of Sec. 958(b) to expand the definition of “U.S. shareholder” to include a U.S. person who owns at least 10% of the value of the shares of the foreign corporation.
The 10.5% figure is associated with GILTIs, yes guilties. You can't make this stuff up. So, what is a GILTI?

From Sec. 951A
The Act adds to the Code new Section 951A, which requires a United States shareholder of a controlled foreign corporation (CFC) to include in income, as a deemed dividend, the global intangible low-taxed income ("GILTI") of the CFC. After factoring in a deduction that a domestic corporation will be entitled to claim with respect to such income inclusion, a domestic corporation will be subject to U.S. tax on GILTI at an effective rate of 10.5% (that is, 50% of the U.S. corporate tax rate of 21%).

For purposes of this rule, "GILTI" is defined as the excess of the U.S. shareholder's net CFC tested income over a net deemed tangible income return. "Net CFC tested income" generally means a CFC's gross income, other than income that is subject to U.S. tax as effectively connected income, Subpart F income (including income that would be Subpart F income but for the application of certain exceptions), and foreign oil and gas extraction income, less allocable deductions. The "net deemed tangible income return" generally is an amount equal to (i) 10% of the aggregate of the United States shareholder's pro rata share of a CFC's qualified business asset investment (generally, a quarterly average of the CFC's tax basis in depreciable property used in its trade or business) over (ii) the amount of interest expense taken into account to determine such U.S. shareholder's net CFC tested income.

Under the Act, a domestic corporation is entitled to a credit for 80% of its pro rata share of the foreign income taxes attributable to the income of the CFC that is taken into account in computing its net CFC tested income. The foreign tax credit limitation rules apply separately to such taxes, and any taxes that are deemed paid under these rules may not be carried back or forward to other tax years.

This provision is effective for taxable years of foreign corporations beginning after December 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.
Tax Reform Act ? Impact on Taxpayers with International Operations | Ideas | Ideas | Baker Botts LLP

Maybe you can explain this. I'm not sure.
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Old January 13th, 2018, 12:09 PM   #34
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IT but strange thing is happening 100s of Billions of dollars have been invested IN the US. While During the Obama administration Companies were Fleeing the states.

Even Companies Obama gave Big Tax Breaks. Like GE.
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Old January 13th, 2018, 06:18 PM   #35
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Quote:
Originally Posted by imaginethat View Post
Here's the language from the tax bill:
Foreign intangible income: The act provides domestic C corporations (that are not regulated investment companies or REITs) with a reduced tax rate on “foreign-derived intangible income” (FDII) and “global intangible low-taxed income” (GILTI). FDII is the portion of a domestic corporation’s intangible income that is derived from serving foreign markets, using a formula in a new Sec. 250. GILTI would be defined in a new Sec. 951A.

The effective tax rate on FDII will be 13.125% in tax years beginning after 2017 and before 2026 and 16.406% after 2025. The effective tax rate on GILTI will be 10.5% in tax years beginning after 2017 and before 2026 and 13.125% after 2025.

Definition of U.S. shareholder: The act amended the ownership attribution rules of Sec. 958(b) to expand the definition of “U.S. shareholder” to include a U.S. person who owns at least 10% of the value of the shares of the foreign corporation.
The 10.5% figure is associated with GILTIs, yes guilties. You can't make this stuff up. So, what is a GILTI?

From Sec. 951A
The Act adds to the Code new Section 951A, which requires a United States shareholder of a controlled foreign corporation (CFC) to include in income, as a deemed dividend, the global intangible low-taxed income ("GILTI") of the CFC. After factoring in a deduction that a domestic corporation will be entitled to claim with respect to such income inclusion, a domestic corporation will be subject to U.S. tax on GILTI at an effective rate of 10.5% (that is, 50% of the U.S. corporate tax rate of 21%).

For purposes of this rule, "GILTI" is defined as the excess of the U.S. shareholder's net CFC tested income over a net deemed tangible income return. "Net CFC tested income" generally means a CFC's gross income, other than income that is subject to U.S. tax as effectively connected income, Subpart F income (including income that would be Subpart F income but for the application of certain exceptions), and foreign oil and gas extraction income, less allocable deductions. The "net deemed tangible income return" generally is an amount equal to (i) 10% of the aggregate of the United States shareholder's pro rata share of a CFC's qualified business asset investment (generally, a quarterly average of the CFC's tax basis in depreciable property used in its trade or business) over (ii) the amount of interest expense taken into account to determine such U.S. shareholder's net CFC tested income.

Under the Act, a domestic corporation is entitled to a credit for 80% of its pro rata share of the foreign income taxes attributable to the income of the CFC that is taken into account in computing its net CFC tested income. The foreign tax credit limitation rules apply separately to such taxes, and any taxes that are deemed paid under these rules may not be carried back or forward to other tax years.

This provision is effective for taxable years of foreign corporations beginning after December 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.
Tax Reform Act ? Impact on Taxpayers with International Operations | Ideas | Ideas | Baker Botts LLP

Maybe you can explain this. I'm not sure.


Fuck no. I cant read whateve language that is. Sounds like the feds want a cut of monies you make outside of the US.

We should be 100% against that.
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