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FOREIGN INCOME & TAXPAYERS

GILTI and Subpart F treatment of distributions of appreciated property

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.

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.