Final Rules on Global Intangible Low-Taxed Income Near Release

Final rules implementing one of the key international provisions of the 2017 tax overhaul may be published soon.

• The White House’s Office of Management and Budget on June 6 completed its review of Section 951A, which determines how “global intangible low-taxed income” is taxed, and sent the rules back to the Treasury Department.
• The tax is meant to kick in if a company is paying a low tax rate—below 13.125%—in foreign countries.
• GILTI ensures that companies pay at least some tax on their foreign income by imposing a 10.5% rate on profits that are above a deemed ...