Application of GILTI

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bobbiejeanhuff
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Joined: Wed Feb 20, 2019 1:06 pm

Application of GILTI

Post by bobbiejeanhuff »

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.
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