Strategizing Multinational Tax Risks

The confusion over details of the US Tax Act continues, among them:

GILTI: Literal application of the Sec. 78 gross-up component to the general basket (As a calendar-year public company nears the end of the year, this decision will become more significant as millions of dollars in tax liabilities and income tax provisions are in play)

GILTI: Vagaries into the US expense allocations, including interest and R&D

Interest: Interpretation (proposed regulations to be issued although no timeline, different types of business, gross receipts test

Upcoming Bluebook for issues needing technical correction, although political agreement may be difficult for such guidance

Technical corrections: slim chance this year

EY’s Global Alert provides additional details of these issues,

Click to access 2018G_02657-181Gbl_Report%20on%20recent%20US%20international%20tax%20developments%20-%204%20May%202018.pdf