Application of GILTI

This is our main tax information forum which deals with topics concerning Canadians living and working in the U.S., U.S. citizens contemplating working in Canada, and all aspects of Canadian and U.S. income tax and related adminstrative issues.

Moderator: Mark T Serbinski CA CPA

Post Reply
bobbiejeanhuff
Posts: 1
Joined: Wed Feb 20, 2019 1:06 pm

Application of GILTI

Post by bobbiejeanhuff » Thu Feb 21, 2019 4:46 pm

In evaluating tax owing for 2018 under GILTI for a US owner of a Canadian corp:
(1) Do the financial statements of the Canadian firm need to be updated to a calendar year end if the YE for the firm is October 31st?
(2) Does depreciation need to be calculated under rules different from those normally applied in Canada?
(3) If the owner became a US person in 2016, is the tax calculated only for the period for which the owner has been a US person?
Thank you.

Post Reply