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Expert Analysis

Foreign Tax Credit Guidance Provides Limited GILTI Relief

By Martin Hamilton, Martine Seiden Agatston and Yomarie Habenicht (December 7, 2018, 12:46 PM EST) -- The Tax Cuts and Jobs Act, passed at the end of 2017, included a significant overhaul to the taxation of foreign-source income. Among these changes were the introduction of a new tax regime under Section 951A[1] addressing "global intangible low-taxed income," or GILTI, that subjects U.S. shareholders to a 10.5 percent tax on income earned through foreign subsidiaries that has not been subject to a certain minimum rate of taxation.[2]...

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