[{"articleAbstract":"Under the Subpart F regime, income subject to the regime is initially defined by what it includes, while under the GILTI regime, income subject to the regime is initially defined by what it excludes. This article discusses the application of these different approaches in the context of nonliquidating distributions from a controlled foreign corporation to a U.S. shareholder.","articleTitle":"GILTI and Subpart F treatment of distributions of appreciated property","externalizedPath":null,"featureImage":{"imageTagAttributes":{"src":"/etc/designs/default/resources/0.gif","alt":"","title":"","class":"cq-image-placeholder"}},"page":{"path":"/issues/2021/feb/gilti-subpart-f-distributions-appreciated-property"},"sortDate":"2021-02-01T05:00:00.000-05:00"},{"articleAbstract":"This article examines the different contribution and distribution rules for the two types of plans.","articleTitle":"Sec. 457 government plan distributions compared to 401(k) distributions","externalizedPath":null,"featureImage":{"imageTagAttributes":{"src":"/etc/designs/default/resources/0.gif","alt":"","title":"","class":"cq-image-placeholder"}},"page":{"path":"/issues/2021/feb/sec-457-government-plan-401k-distributions"},"sortDate":"2021-02-01T05:00:00.000-05:00"},{"articleAbstract":"Tax-exempt Sec. 501(c)(3) charities, public schools, and certain other entities can generally adopt either Sec. 403(b) or Sec. 401(k) retirement plans. While the rules applying to these plans are often substantially the same, there are many significant differences.","articleTitle":"Sec. 403(b) retirement plans: A comparison with 401(k) plans","externalizedPath":null,"featureImage":{"imageTagAttributes":{"src":"/etc/designs/default/resources/0.gif","alt":"","title":"","class":"cq-image-placeholder"}},"page":{"path":"/issues/2021/jan/retirement-plans-comparison-401k-sec-403b"},"sortDate":"2021-01-01T05:00:00.000-05:00"},{"articleAbstract":"This article discusses income-based plans and how married couples with student loan debt may minimize their current loan payments by filing separately instead of jointly.","articleTitle":"The impact of filing status on student loan repayment plans","externalizedPath":null,"featureImage":{"imageTagAttributes":{"src":"/etc/designs/default/resources/0.gif","alt":"","title":"","class":"cq-image-placeholder"}},"page":{"path":"/issues/2021/jan/student-loan-repayment-plans-impact-of-filing-status"},"sortDate":"2021-01-01T05:00:00.000-05:00"}]