Tax Notes International / Tax Notes Federal – CFCs and the Individual Shareholder (Tax Notes, 2020.9.)

By Jaehong Lee

In this article, H. David Rosenbloom (a member with Caplin & Drysdale Chtd. in Washington and director of the international tax program at New York University School of Law) and Jae Hong Lee describe how the subpart F and global intangible low-taxed income (GILTI) rules affect the taxation of income of individual shareholders of controlled foreign corporations. 

CFCs and the Individual Shareholder