All tagged PTE

The 2017 Tax Cut and Jobs Act (TCJA) had many provisions, which we will be discussing over the next few months, and they include good, bad, and ugly. Some are two-faced, with aspects that at first seem bad but may actually turn out to be a blessing depending on your situation. One such provision is the GILTI regime, a new category of “Subpart F” income intended to prevent inappropriate deferral of foreign source income by U.S. taxpayers.