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2021 Senate Finance International Tax Discussion OnPoint

Changes are coming to the international tax provisions of the TCJA, and this easy-to-read OnPoint presentation will highlight all you need to know about these tax proposals.

This vital resource summarizes the Senate Finance Committee’s draft legislation, including:

Changes to the GILTI regime:

  • Eliminate DTIR and QBA from GILTI calculation
  • Calculate on country-by-country basis
  • Only tested income that is not high-tax test income would be subject to U.S. tax

Changes to the subpart F regime and foreign tax credit:

  • Extend high-tax rules to foreign branch income
  • Apply haircut for subpart F foreign tax credits
  • Conform treatment of high-tax subpart F income
  • Treat R&E expenses and stewardship expenses as 100% allocable to U.S.-source income

Changes to the §250 deduction and FDII:

  • Reduce and equalize §250 deduction for FDII and net CFC tested income
  • Eliminate DTIR and QBAI from FDII calculation
  • Clarify that §78 gross-up amount is included for purposes of taxable income limitation


Download this ready-to-share presentation today and help your clients prepare for these potential changes.

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