.... In this article, we briefly review the history of U.S. international tax policy and analyze the technical aspects of GILTI. We then discuss some general tax planning strategies and propose four specific tax strategies for companies to consider for minimizing the increased tax burden associated with GILTI. Last...

... are reclassified as a Code Section 301 distribution resulting in dividend treatment and allowing recovery of the selling shareholder's stock basis only after E&P is exhausted. Editor's note: Accepted by Blaise M. Sonnier. April 2019 October 2019 2019 corporate tax international...