August 30, 2018

Proposed [Global Intangible Low-Taxed Income] GILTI regulations pending OIRA review; IRS draft forms for GILTI reporting

Editor’s Note: See Jim Tozzi on OMB Review of IRS Regulations.

From: KPMG

The new tax law in the United States generally retained the existing subpart F regime that applies to passive income and related-party sales, but a new, broad class of income—“global intangible low-taxed income” (GILTI)—was created. GILTI is also deemed repatriated in the year earned and, thus, is also subject to immediate taxation. GILTI income is effectively taxed at a reduced rate while subpart F income is taxed at the full U.S. rate. In general, GILTI is the excess of all of the U.S. corporation’s net income over a deemed return on the CFC’s tangible assets (10% of depreciated tax basis).

For purposes of implementing the GILTI rules, proposed regulations are pending review, and the IRS has released draft versions of forms related to the GILTI rules.

Proposed regulations in OIRA review

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