Aug 21, 2020
There are a couple of developments on the GILTI front that readers may find interesting. First, last month the IRS issued final and proposed regulations involving GILTI and the high-tax exclusion. Second, one of Democratic U.S. Presidential nominee Joe Biden’s tax proposals is the doubling of the effective GILTI corporate tax rate from 10.5% to 21%.
To understand the potential impact of these, you first need to have a general understanding of what the GILTI provisions are meant to do and their current impact.