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.
Tag Archives: Section 951A
First Round of Proposed GILTI Regulations Avoids the Hard(er) Stuff
▪ Written 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. [...]Read more