BTAX OnPoint: GILTI Collides with Pillar 2 Minimum Taxes

There is renewed attention on the US Global Intangible Low-taxed Income (GILTI) taxing structure and its interaction with new minimum tax rates taking effect around the world under the international Pillar 2 initiative. These taxes focus on the largest multinational companies and their cross-border operations.

GILTI differs from standard Pillar 2 minimum income tax structure. Tax authorities are examining how the U.S. might align with the international Pillar 2 initiative.

This attention highlights the importance of understanding GILTI calculations, which apply to U.S.-based companies with foreign corporations. While the Pillar 2 minimum income taxes are targeted at reaching a minimum ...