Transfer Pricing Report

Final Rules ‘Imminent’ on Foreign Income Tax Opt-Out (Corrected)

Jan. 23, 2020, 6:29 PMUpdated: Jan. 24, 2020, 7:51 PM

Final rules for companies looking to elect out of the 2017 tax law’s levy on a new category of foreign income are “imminent,” a Treasury Department official said Thursday.

Wade Sutton, deputy international tax counsel at Treasury’s Office of Tax Policy, didn’t elaborate when asked for more details on timing. Sutton spoke at a conference hosted by the D.C. Bar on Thursday.

  • The 2017 overhaul created global intangible low-taxed income (GILTI), under tax code Section 951A, which is designed to ensure companies pay a minimum tax on offshore profits in low-tax countries. A corresponding 10.5% levy is intended to...
To read the full article log in. To learn more about a subscription click here.