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Final Rules May Help Companies Unintentionally Hit by Global Tax

May 11, 2019, 5:23 PM

Treasury may include an exception for certain multinationals in forthcoming final regulations on an international provision meant to ensure companies pay a minimum levy on offshore profits in low-tax countries.

Companies might be paying a tax on global intangible low-taxed income (GILTI) for overseas earnings even if their offshore tax rate is well over 13 percent, and that is because they are allocating deductions, said Gary Scanlon, attorney-adviser in the Treasury Department’s Office of International Tax Counsel.

“What people are asking for is if the foreign earnings are taxed at a certain rate, that should just be kicked out ...

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