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Daily Tax Report: International

Rules for Foreign Income Tax Opt Out Under White House Review

June 17, 2020, 11:31 AM

Final rules on how companies can opt out of a category of foreign income created by the 2017 tax law are now under White House review.

  • The 2017 tax law introduced a new category of foreign taxable income called global intangible low-taxed income, or GILTI, under Section 951A of the tax code. The rule, which reached the Office of Information and Regulatory Affairs June 16, is aimed at ensuring companies pay at least a minimum tax on offshore profits in low-tax jurisdictions.
  • The high-tax exclusion helps alleviate problems for companies hit with the 10.5% GILTI tax, despite paying more...

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