Private Equity Seeks Treasury Help to Avoid Offshore Tax Hit

Private equity funds are asking Treasury to help them avoid a tax hit on offshore income.

Treasury is working on finalizing rules that would allow companies already paying at least 18.9% in taxes offshore to opt out of taxes on two types of offshore income—global intangible low-taxed income (GILTI) and Subpart F income.

But some investment funds’ portfolio companies will have a difficult time qualifying for the exclusion because of how they operate. Instead, they want a special carve-out from what is known as the consistency rule.

The rule requires that the election be made across all members of the ...