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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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Compares book depreciation to tax depreciation, identifies differences, and prepares supporting schedules. Useful for both compliance and provision teams.

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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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Tax research memo template (issue, facts, analysis, conclusion)

Produces a structured tax research memo with clear issue framing, facts, analysis, and conclusion placeholders. Useful for staff and seniors standardizing technical writing quality.

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