futures – The expansion of the Subpart F Regime to active business income

The TCJA established the principle of subjecting the shareholder to taxation on ACTIVE BUSINESS income earned by the corporation:

Retroactively – The Section 965 Transition Tax imposed taxation on the shareholder to ACTIVE BUSINESS income earned by corporations from 1986 to 2017

Prospectively – The Section 951 GILTI Tax imposed taxation on ACTIVE BUSINESS income earned by corporations from January 1, 2018

Imagine how this would effect individual Americans abroad who are simply trying to run small businesses (in the form of a small business corporation) in their country of residence. Those individuals are now subject to taxation in the following ways:

By their country of residence (in a moment I will use Israel as an example)

– their corporations arePrioritisation of teaching topics in obstetrics and gynaecology: a Delphi survey of postgraduate trainees.
Topics for theoretical teaching during the obstetrics and gynaecology specialty training programme are often chosen by tutors, with little input from the trainees. However, it is important to actively involve adults in their learning process to maintain their learning ownership and motivation. The Delphi methodology is a generic social science technique used to aggregate views and opinions of experts, the community and service users. In this study, we conducted a two generational Delphi study to achieve consensus between a group of trainees in obstetrics and gynaecology, regarding what they considered important topics for inclusion in their protected teaching programme. A total of 25 trainees from one deanery, participated in this study. We were able to