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EPGD Law Blog

Tag: foreign partner
Tax Law
Niuris Bezanilla

Foreign Partnerships & Tax Form 8813

Under Internal Revenue Code “IRC” Section 1446, a partnership of this sort may be made up of any kind of foreign corporation, international organization, non-resident individual or foreign estate or trust. Any partnership that falls under the definition of 1446 must pay the required withheld taxes mandated by the IRS.

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Foreign Reporting
Eric Gros-Dubois

What’s the Deal with GILTI?

Introduced in 2017 as part of the Tax Cuts and Jobs Act, GILTI, or “Global Intangible Low Tax Income,” is an outbound provision that broadens the scope of foreign earnings subject to U.S. taxation with the goal of reducing the incentive to shift corporate profits out of the U.S. into low or zero-tax jurisdictions.[1] Applicable to large multinational companies and to U.S. shareholders of certain foreign corporations, GILTI is fundamentally an anti-deferral provision that limits the amount of foreign income a U.S. shareholder can defer from U.S. tax.

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