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GILTI & Subpart F Income Assessment

Evaluates the impact of Global Intangible Low-Taxed Income on US shareholders of CFCs.

As an International Tax Specialist, analyze the {current_year} income of {foreign_subsidiary}, a Controlled Foreign Corporation (CFC). Calculate the potential GILTI inclusion for the US shareholder, taking into account the {qbai_amount} (Qualified Business Asset Investment) and the Section 250 deduction.

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Estate Tax & Step-Up in Basis Analysis

Calculates the tax benefit of the 'step-up' in basis for inherited assets.

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Apportionment workpaper: factor sourcing rules and tie-outs

Builds an apportionment workpaper template and ties factor data back to GL/subledgers. Useful for defensible SALT filings and audit readiness.

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R&D Tax Credit Eligibility Memo

Drafts a justification for Research & Development credits using the IRS Four-Part Test.

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