Analysis

Closing Gaps In GILTI Opens Up Authority Questions

Law360 (June 19, 2019, 8:49 PM EDT) -- Recent rules on the international provisions of 2017's tax law attempt to resolve gaps and contradictions in the legislation's framework for global intangible low-taxed income — and in doing so, raise questions about whether they exceed regulatory authority.

Four regulations recently issued by the U.S. Treasury are expected to be the last for the federal tax overhaul's international provisions before a key deadline on June 22. (AP) The regulations, released by the U.S. Department of the Treasury on Friday, include a new proposed rule creating a high-tax exception to the Tax Cuts and Jobs Act's GILTI provision, as well as final...

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