Tax Reform & Subpart F: The good, the bad and what to do about it.

[@621jihoonkim]

what's the diff between in Subpart F and GILTI?

[@ntb137]

I'm finding this 50% of shareholders being US persons, being thrown around a lot. It says on the IRS site more than 50%. But then ten percent keeps coming up. From what I gather, if you own 10% or more, you're considered a shareholder, but that alone doesn't make you Cfc. US Shareholders hold 50% of shares shouldn't be Cfc because it is not MORE THAN 50%. and no need for subpart F? Am I getting this right? Thanks for the video.

[@irsmedic]

Yes, you got it! If you have 11 US shareholders, each with 9% interest, that is NOT a CFC. Even though is is 100% US owned and controlled!

[@vinu1505]

IRS Medic I heard, it is 10% or more of value or rights, so is that qualifies as CFC? If not, will this have any implications with §958c?

[@Ashutosh.Dhriti22]

Hi So now since is the US is moving away from the worldwide tax system to territorial tax system so do you think FATCA will loose its relevance, since it was introduced to based on a notion that US has a worldwide tax ... Any thoughts on that.?

[@irsmedic]

I have limited faith in a reasonable outcome. The best hope is for the GOP to get a super-majority in November so that they can fix the things they couldn't through reconciliation.