What are the key differences between Subpart F income and GILTI?
I'm trying to understand the difference between Subpart F and GILTI. They both seem to tax CFC income currently to U.S. shareholders. If GILTI was supposed to be a catch-all for everything not already covered by Subpart F, why do we need both? What are the practical differences in terms of what income is covered, tax rates, deductions, and foreign tax credits? This is driving me crazy.
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