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.