The Portfolio describes who is subject to GILT, which was designed to discourage American corporates from corporations from shifting their intangible income offshore to low-tax foreign jurisdictions to changes introduced by the Tax Cuts and Jobs Act of 2017.

Bloomberg’s announced noted that law “redesigned the U.S. international income taxation system to a territorial regime, under which foreign earnings of a U.S. corporation’s foreign subsidiaries are not subject to U.S. income tax when earned or distributed to the U.S. parent corporation, but instead taxed under local jurisdictions.”

GILTI provisions impose a minimum rate of U.S. income tax on select types of foreign income earned by controlled foreign corporations. This Portfolio addresses the simultaneous equations involved with GILTI computation, allocation, and apportionment rules, as well as the §250 deduction, with numerous examples.

Bob Scott

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Bob Scott has provided information to the tax and accounting community since 1991, first as technology editor of Accounting Today, and from 1997 through 2009 as editor of its sister publication, Accounting Technology. He is known throughout the industry for his depth of knowledge and for his high journalistic standards.  Scott has made frequent appearances as a speaker, moderator and panelist and events serving tax and accounting professionals. He  has a strong background in computer journalism as an editor with two former trade publications, Computer+Software News and MIS Week and spent several years with weekly and daily newspapers in Morris County New Jersey prior to that.  A graduate of Indiana University with a degree in journalism, Bob is a native of Madison, Ind