Foreign Credits At Risk In Senate Tax Bill, Analysts Say

Law360, New York (November 16, 2017, 7:25 PM EST) -- A provision in the Senate’s version of the Tax Cuts and Jobs Act requiring U.S. multinationals to calculate their foreign tax credits on an annual basis means that companies could end up with unusable leftover credits and bookkeeping anomalies due to mismatches with other countries’ accounting rules, tax specialists say.

Applying the current foreign tax credit regime to the bill's new category of intangibles income — global intangible low-taxed income, or GILTI — would allow multinational businesses to reduce the income in part by factoring in pooled foreign tax credits. As the foreign tax currently applies, U.S. companies with foreign subsidiaries that pay...

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