US tax reform: GILTI uncertainties
International Tax Review is part of the Delinian Group, Delinian Limited, 4 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

US tax reform: GILTI uncertainties

gilti-carousel.jpg

For months, Congress promoted the tax reform effort as being focused on simplifying the outdated and complex 1986 Tax Code. Tax reform, culminating in H.R. 1, did no such thing, at least where it applies to multinational US corporations. Nowhere is this more apparent than in section 951A, the tax on global intangible low-taxed income, or ‘GILTI’. Erik Christenson, partner at Baker McKenzie, and Monte Silver, senior counsel at Eitan, Mehulal & Sadot explain.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login
more across site & bottom lb ros

More from across our site

Nigeria looks to boost inefficient tax collection, Singapore plans to hit GST fraudsters hard, Italy and UK confirm reciprocity of VAT refunds, and more
The UK is also lagging behind other countries in use of technology for compliance purposes, Christiaan Van Der Valk argues
As a new agreement between India and Mauritius may unsettle foreign investment, Sanjay Sanghvi and Avin Jain of Khaitan & Co examine the possible impact and offer potential solutions
A vast majority of corporates – especially smaller businesses – rely on a trusted referral when instructing external counsel, according to a survey of nearly 29,000 in-house counsel
It comes as the US remains uncommitted to the pillar two rules; in other news, ‘Bitcoin Jesus’ faces charges over tax evasion and false tax returns
The US is capitalising on a fertile deals market to take centre stage in tax talent recruitment, according to insights from ITR+’s Talent Tracker
The EU’s CBAM is a considerable compliance task for any in-scope companies. As payments loom for many businesses from 2026, tax departments will need to step up and take the lead
The firm also pledged to boost its commitment to AI and reinventing clients’ business models
High-earning businesses place most value on the depth of the external legal teams advising them, according to a survey of nearly 29,000 in-house counsel
Pillar two is bound to create a compliance challenge for clients, but the desirability of tax professionals has never been higher, the ITR forum heard
Gift this article