Our Federal Tax Group explores how Treasury’s proposed regulations could have the global intangible low-taxed income (GILTI) regime operating in a way you might not expect.
Section 951A
First Round of Proposed GILTI Regulations Avoids the Hard(er) Stuff
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. [...]Read more