'IP Come Home!' How TCJA Incentivizes Asset Repatriation

Law360 (March 6, 2018, 10:24 PM EST) -- Much has been written about how the recent Tax Cuts and Jobs Act, P.L. 115-97,[1] is incenting U.S. multinational companies to bring jobs and income home. However, there are two lesser-known related provisions of TCJA specifically targeting more “portable” income. This is income from assets that are easily moved to other countries, such as intellectual property, or IP.[2]

The two provisions — global intangible low-taxed income, or GILTI,[3] and foreign-derived intangible income, or FDII[4] — share a common goal: keeping U.S. companies’ intangible assets home in...
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