GE Official Worries Some Income Could Be Taxed Twice

Dec. 13, 2018, 7:35 PM

Companies fear a provision in the 2017 tax law that could mean they have taxable income without economic income.

The situation arises “where taxable income is imposed on more than the economic income,” said Patrick J. Brown, vice president of tax for GE Power, GE Energy Connections, and GE Renewable Energy. The result comes from an interaction between the new global intangible low-taxed income (GILTI) rules, and older Subpart F rules that classify a U.S. company’s foreign income.

The GILTI rules say that U.S. shareholders owning 10 percent or more of the stock of a controlled foreign corporation—by vote ...

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