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First Round of Proposed GILTI Regulations Avoids the Hard(er) Stuff

September 20, 2018 By Edward Tanenbaum and Heather Ripley

The IRS’s opening salvo of proposed regulations under the Tax Cuts and Jobs Act’s global intangible low-taxed income is as complex as you would think. Our International Tax Group cuts through the clutter to address the key takeaways:

  • Computation of GILTI inclusion
  • Anti-abuse rules
  • GILTI guidance still to come

Read the full advisory here. 

Filed Under: International Tax Advisory, Uncategorized Tagged With: anti-abuse, Base Erosion and Anti-Abuse Tax, CFC, controlled foreign corporation, domestic partnerships, GILTI, IRS, Section 951A, Tax Cuts and Jobs Act, TCJA

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

[Read Bio]

About Heather Ripley

Heather Ripley is an associate in the firm’s Federal & International Tax Group. Her practice focuses on federal and international tax services for a range of clients, including domestic and international business entities and individuals.

[Read Bio]

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