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Exempting GILTI from OECD Global Tax Rate Raises More Questions

Sept. 22, 2020, 8:46 AM

U.S. multinationals’ wish to be excluded from an OECD-led effort to set a global minimum tax rate could come with new administrative burdens.

The nearly 140 countries negotiating a global tax overhaul at the Organization for Economic Cooperation and Development are considering whether to allow U.S. companies a pass on global minimum tax rules, because they’re already subject to a similar regime in the U.S.

Countries would need to figure out several questions, including how to coordinate the two regimes; how to treat U.S. companies with subsidiaries that also have foreign parents; whether other countries will apply their minimum tax ...