The Application and Future of the U.S. Global Intangible Low-Taxed Income Tax
Keywords:
accounting, finance, GILTI, foreign earnings, multinational corporations, intangible assets, Subpart F IncomeAbstract
This paper is prepared to look at a unique tax provision in the United States 2017 Tax Act (Tax Cuts and Jobs Act of 2017) dealing with foreign earnings of United States multinational firms engaged in business activities in many countries worldwide. This act dramatically changed the tax status of typical foreign earnings of United States multinational corporations as far as United States taxation is concerned. However, in light of this dramatic change, the unique tax provision that was also added in the United States tax law in the 2017 Tax Act that this article addresses tries to ensure that that dramatic change in the tax status of typical foreign earnings of United States multinational corporations did not go too far. This paper looks at this unique tax provision in terms of its purpose, application and, as much as possible, its future in United States tax laws.
References
American Action Forum. (2018, September 13). Global Intangible Low-Taxed Income Taxation – A Primer Gordon Gray.
Bloomberg Tax & Accounting. (n.d.). A Special Report Global Intangible Low-Taxed Income (Gilti) Regulations Roadmap.
Congressional Research Service. (2021, December 16). Issues In International Corporate Taxation: The 2017 Revision (P.L. 115-97).
FASB. (n.d.). Financial Accounting Standards Board: Topic 740, No. 5: Accounting For Global Intangible Low-Taxed Income.
Internal Revenue Code of 1986.
Kpmg: Tax Reform. (2018, February 6). Kpmg Report on New Tax Law (Analysis and Observation).
Loughead, K. (2021). Biden Administration Changes to GILTI and FDII Will Yield Automatic State Tax Increases. Tax Foundation Fiscal Fact No. 765.
Raabe, W.A., Young, J.C., Nellen, A., Hoffman, W.H., Maloney, D.M. (2010). Corporations, Partnerships, Estates And Trusts (2022 45th Annual Edition). South-Western Cengage Learning. 2021 Cengage Learning, Inc.
