ARLINGTON, Va., May 17, 2022 /PRNewswire/ — Bloomberg Tax & Accounting today announced the launch of a new tax management portfolio, Global Intangible Low-Taxed Income (GILTI). Written by Libin Zhang of Frank, Harris, Shriver & Jacobson LLP, describes the Portfolio which is subject to GILTI and provides guidance and a detailed discussion on the calculation of GILTI.

The Tax Cuts and Jobs Act of 2017 redesigned the U.S. international income tax system into a territorial regime, under which foreign income from foreign subsidiaries of a U.S. corporation is not subject to income tax American when earned or distributed to the American parent company, but rather taxed. subject to local jurisdictions. To discourage US corporations from transferring their offshore intangible income to low-tax foreign jurisdictions in response to this change, the GILTI provisions were introduced. The provisions of GILTI impose a minimum rate of US income tax on certain types of foreign income earned by controlled foreign corporations.

This portfolio covers the simultaneous equations involved in the GILTI calculation, allocation and distribution rules, as well as the §250 deduction, with many examples. The Portfolio also explains in detail how the special foreign tax credit rules apply to GILTI inclusions.

“Most businesses and many individuals are affected by GILTI due to their overseas operations, and it is important that tax practitioners have a thorough knowledge of all tax rules so that they can correctly identify issues and structure their clients,” Zhang said. , who also wrote the Portfolio on Passive Loss Rules.

“Given the complexity of the U.S. international tax system and GILTI’s important role within it, all individuals and companies that do business overseas will find this portfolio valuable,” said Heather Rothmann, vice president of analytics and content, Bloomberg Tax & Accounting. “by Libin Zhang The expertise will help tax professionals understand and mitigate tax exposure and forecast scenarios to understand the impact of current and upcoming possible changes in this area. »

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