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.
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February 2021 - The Tax Adviser
- Magazine
- February 2021

FOREIGN INCOME & TAXPAYERS
employee benefits & pensions
Sec. 457 government plan distributions compared to 401(k) distributions
This article examines the different contribution and distribution rules for the two types of plans.
TAX CLINIC
corporations & shareholders
DEPRECIATION
expenses & deductions
FOREIGN INCOME & TAXPAYERS
INTEREST INCOME & EXPENSE
partners & partnerships
S CORPORATIONS
STATE & LOCAL TAXES
COLUMNS
TAX PRACTICE RESPONSIBILITIES
CAMPUS TO CLIENTS
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.