U.S. Owners of Foreign Corporations Face New Hurdles

Carl Merino authored an international practice feature article, "U.S. Owners of Foreign Corporations Face New Hurdles," published in the April 2019 issue of Trusts & Estates magazine. The article discusses the impact of the Tax Cuts and Jobs Act of 2017 (TCJA) on U.S. individuals who own stock in controlled foreign corporations, with a focus on the new tax on global intangible low-taxed income (GILTI) and potential mitigation strategies.