Strategizing Multinational Tax Risks

Pursuant to Final and Proposed Regulations recently published, the high-tax exception would be a “unitary” election for both GILTI and Subpart F.

The election is made annually, and can apply retroactively to post-TCJA years.

In summary, Treasury has adopted some taxpayer comments favorably, while delivering an unexpected result in their guidance.

EY’s Alert provides additional background, with links to the Regulations.

https://www.ey.com/en_gl/tax-alerts/us-final-and-proposed-gilti-regulations-deliver-few-benefits-and-more-than-a-few-surprises