Sometimes GILTI Is A Pleasure

By Mitchell Goldberg and Bryan Appel ( January 31, 2019, 1:06 PM EST) -- Usually, when Congress implements a new tax, taxpayers and their tax advisers spend countless hours planning their way around such a new tax. When Congress added the global intangible low-tax income, or GILTI, tax as part of tax reform in December 2017, many of us had the typical reaction described above — how do we avoid GILTI? However, a year of studying and understanding GILTI and the proposed GILTI regulations promulgated by the U.S. Department of the Treasury has caused many to rethink and revisit the implicit aversion to new taxes....

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