GILTI Regulations Roadmap

The newly finalized Section 951A of the Tax Cuts and Jobs Act (TCJA) involved a tax on global intangible low-taxed income (GILTI).

Our comprehensive Global Intangible Low-Taxed Income (GILTI) Regulations Roadmap explores the four provisions within the preamble that were substantially revised between proposal and finalization, including:

Treatment of domestic partnerships
Rule for property transfers during “disqualified period”
Taxpayer provision allowing utilization of alternative depreciation system for earnings and profits
Anti-abuse rule for property held temporarily

Download your complimentary copy to navigate final regulations and primary resources – with international tax implications.

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