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Treasury, IRS issue proposed GILTI rules under tax reform

Tammy Whitehouse | September 14, 2018

The U.S. Treasury and the Internal Revenue Service have issued proposed new regulations on how to calculate global intangible low-taxed income under the Tax Cuts and Jobs Act.

The proposed GILTI regulations address implementation of key provisions of the 2017 tax reform law, which attempts to modernize the U.S. approach to income taxation and shift the focus from a worldwide system to a territorial system, said Treasury Secretary Steven Mnuchin in a statement. “We are providing clarity to taxpayers and closing loopholes that previously allowed for inappropriate international tax planning and shifting profits overseas,” he said.

Under the GILTI provisions of the Tax Cuts and Jobs Act, U.S....

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