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Treasury Mulls Ways to Allocate Minimum Tax If Fallback Needed

June 28, 2022, 6:28 PM

The Treasury Department is looking at ways to attribute US taxes on foreign income to each country where they’re generated, because that breakdown might be needed if the US isn’t fully aligned with OECD’s plans for a global minimum tax.

The alternatives for attributing taxes country-by-country would apply if Congress doesn’t approve changes in the US global intangible low-taxed income—known as GILTI—that are deemed necessary for it to qualify as an equivalent to the 15% minimum tax planned as part of the global tax deal.

If Congress fails to act, Treasury officials have said GILTI would still be treated as ...