MNEs get easy ride under US repatriation and GILTI regimes as US expats pick up the bill

May 22 2018

Although the 2017 US Tax Cuts and Job Act (TCJA) aimed to cut taxes for all Americans, individual US shareholders of controlled foreign corporations (CFCs) living outside the US (expats) are being discriminated against under the repatriation and GILTI tax regimes. Monte Silver of Silver & Co in Israel explains why the likes of Google and Apple are getting a good deal.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

A taxing week: Carney’s Davos speech could inspire a challenge to US tax dominance

If Trump continues to poke the world’s ‘middle powers’ with a stick, he shouldn’t be surprised when they retaliate

Sam Sholli, February 06 2026

Direct Tax

This week in tax: Triodos Bank achieves Fair Tax Mark in industry first

The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas

Sam Sholli, February 06 2026

Direct Tax

Businessman putting a card with text code of ethics in the pocket

‘Spending time in a gentleman’s club’: CLG sacks CEO

Zion Adeoye, a tax specialist, had been suspended from the African law firm since October over misconduct allegations

Sam Sholli, February 05 2026

Direct Tax

Close up shake hands, Considering buying a home, investing in real estate. Broker signs a sales agreement. agent, lease agreement, successful deal.

Ryan continues acquisition drive with Scottish property tax firm buyout

The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said

Tom Baker, February 05 2026

Indirect Tax

This month in indirect tax: US and India strike trade deal, tariffs reduced

Trump announced he will cut tariffs after India agreed to stop buying Russian oil; in other news, more than 300 delegates gathered at the OECD to discuss VAT fraud prevention

Sam Sholli, February 04 2026

Transfer Pricing

Experienced MAP jurisdictions should develop TP experts: OECD

Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said

Sam Sholli, February 03 2026

Direct Tax

KPMG launches tax AI programme, unveils Duke Energy as participant

The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’

Tom Baker, February 03 2026

Direct Tax

Indian court reinforces physical presence as cornerstone of service PE

The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals

Karanjot Singh Khurana, February 03 2026

Direct Tax

Business process management and workflow automation diagram with

International tax outlook 2026: digitalisation, AI acceleration, and ongoing fragmentation

User-friendly digital tax filing systems, transformative AI deployment, and the continued proliferation of DSTs will define 2026, writes Ascoria’s Neil Kelley

Neil Kelley, February 02 2026

Direct Tax

HMRC engagement over R&D claims has ‘incrementally improved’: ForrestBrown advisers

Case workers are ‘still not great’ but are making fewer enquiries, making the right decision more often and are more open to calls, ITR has heard

Sam Sholli, February 02 2026