In March, the IRS issued proposed regulations that cover determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate the FDII and GILTI deduction with other tax provisions. Here’s an overview.
Background
The Tax Cuts and Jobs Act (TCJA) established a “participation exemption system” under which certain earnings of a foreign corporation can be repatriated to a corporate U.S. shareholder without U.S. tax. (This occurs under Internal Revenue Code Section 245A.) (more…)
By Sylvia Chan, CPA, Tax Manager
The Tax Cut and Jobs Act (TCJA), P.L. 115-97 enacted in December 2017 has brought about exciting changes to the tax world. I would like to draw your attention to a provision that was written specifically to encourage U.S. companies to expand their operations globally without leaving the United States. Some technology companies have moved their intangible assets offshore to low-income tax jurisdictions and shifted the related income outside the United States. While tax-avoidance may not always be the primary motive, it was an inevitable truth that the U.S. Treasury was losing a portion of its revenue due to this income shifting tactic. (more…)
