On June 14, the U.S. Department of Treasury (Treasury) and the IRS released final regulations for the tax on Global Intangible Low Taxed Income (GILTI), a provision that came from the tax reform law commonly known as the Tax Cuts and Jobs Act (TCJA). Concurrently, the Treasury and IRS released proposed regulations on Subpart F inclusions.
Topics: Private Equity & Venture Capital, PE/VC, portfolio companies, GILTI, global intangible low-taxed income
On Sept. 13, 2018, the Treasury and IRS released proposed regulations related to the enactment of the tax on global intangible low-taxed income (“GILTI”). GILTI was included as part of the 2017 tax reform law introduced as the Tax Cuts and Jobs Act (TCJA). The proposed regulations address several areas, including computational, definitional and anti-avoidance rules for GILTI. The guidance includes provisions applicable to partnerships as well as consolidated groups, but leaves open many questions related to look-through treatment for foreign tax credits, and the interaction with other newly enacted code sections.
Topics: Private Equity & Venture Capital, PE/VC, portfolio companies, GILTI, global intangible low-taxed income
