Global Intangible Low-Taxed Income (GILTI)
Contents
Exploring Global Intangible Low-Taxed Income (GILTI): A Guide to U.S. Taxation of Foreign Corporate Earnings
Discover the intricacies of Global Intangible Low-Taxed Income (GILTI) and its impact on U.S. taxation of income earned by foreign corporations. Learn about the rationale behind GILTI, its calculation, and the implications for multinational companies operating in a global economy.
Understanding GILTI: An Overview
Unravel the concept of GILTI, a specialized tax regime designed to prevent erosion of the U.S. tax base by multinational corporations. Explore how GILTI targets income from intangible assets and aims to deter profit-shifting strategies to low-tax jurisdictions.
Key Takeaways on GILTI Taxation
- GILTI taxes income earned abroad by U.S.-controlled foreign corporations (CFCs) from intangible assets.
- The tax on GILTI ranges from 10.5% to 13.125%, aimed at discouraging profit shifting to jurisdictions with lower tax rates.
- Proposed IRS regulations seek to address unintended tax consequences and prevent excessive taxation of GILTI earned in high-tax countries.
How GILTI Taxation Works: A Deep Dive
Dive into the mechanics of GILTI taxation, including its calculation and implications for CFC shareholders. Understand the complexities of determining GILTI income and the impact of foreign tax credits on effective tax rates.