The Portfolio describes who is subject to GILT, which was designed to discourage American corporates from corporations from shifting their intangible income offshore to low-tax foreign jurisdictions to changes introduced by the Tax Cuts and Jobs Act of 2017.

Bloomberg’s announced noted that law “redesigned the U.S. international income taxation system to a territorial regime, under which foreign earnings of a U.S. corporation’s foreign subsidiaries are not subject to U.S. income tax when earned or distributed to the U.S. parent corporation, but instead taxed under local jurisdictions.”

GILTI provisions impose a minimum rate of U.S. income tax on select types of foreign income earned by controlled foreign corporations. This Portfolio addresses the simultaneous equations involved with GILTI computation, allocation, and apportionment rules, as well as the §250 deduction, with numerous examples.