Trump Tax Plan Likely Incentivizes Globalization
It looks like Trump is just another neocon.
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Synthetic carbo-polymers got em through man. They got em through mouse. They got through, and we're gonna get out.
-Roostre
READ THIS -> https://represent.us/
This guy is a terrible reporter, possibly a propagandist.
1. These specific tax changes were supposedly about "repatriation of money", incentivizing companies to move foreign earned money back to the US. (Just search Google "Trump repatriation").
http://www.businessinsider.com/trump-ta ... eas-2017-9
2. So, the guy starts off wrong. This was never about "stopping companies from moving their profits overseas". Again, it was supposedly the opposite, it's about incentivizing "repatriation of foreign earned money" (bringing foreign earned money back to the US).
3. This guy's premise is wrong. There was never a "disincentive rhetorical push". Again, it was the opposite, it was supposedly about incentivizing "repatriation of foreign earned money".
4. The guy doesn't even both to explain GILTI and FDII.
GILTI : "Generally, income that is Effectively Connected Income, Foreign Base Company Income, or income that is taxed at a rate that is more than 18.9% will not be GILTI".
https://www.withum.com/kc/what-the-fdii ... an-to-you/
So, yes, it appears Congress wrote GILTI to exclude directly connected foreign subsidiaries from getting the preferential repatriation taxation treatment. That's what this guy is seeing.
He doesn't understand the larger picture because he's simply pointing to a few sentences and making a sweeping conclusion off those sentences.
These tax accountants explain how if you have directly-connected subsidiaries then you may need to look at this and possibly restructure your subsidiaries to get the preferential tax treatment. Looks like simply changing a subsidiary to a "C-Corp" would overcome the exclusion.
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After a failure, the easiest thing to do is to blame someone else.
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