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Analysis

Proposed GILTI Regs' Anti-Abuse Rule Seen As Overly Broad

Law360 (September 17, 2018, 7:38 PM EDT) -- Proposed U.S. regulations for the global minimum tax on intangible income contain an anti-abuse provision that could allow the Internal Revenue Service to disregard the effects of certain offshore transactions even if there aren’t signs of tax avoidance, specialists say.

A provision of Treasury's initial proposed rules on global intangible low-taxed income essentially disregards the effects of certain overseas transactions. (AP) The tax on global intangible low-taxed income, or GILTI —  one of a handful of international provisions in the U.S. Tax Cuts and Jobs Act — was intended to prevent companies from taking advantage of a new exemption on most foreign profits...

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