The Resource GILTI : the co-operative potential of a unilateral minimum tax

GILTI : the co-operative potential of a unilateral minimum tax

Label
GILTI : the co-operative potential of a unilateral minimum tax
Title
GILTI : the co-operative potential of a unilateral minimum tax
Creator
Subject
Language
eng
Summary
Prior to the Tax Cuts and Jobs Act of 2017 (TCJA), the US allowed US parented multinationals to delay indefinitely their payment of US corporate income tax on non-US income earned by non-US corporate subsidiaries (CFCs). The TCJA revoked this permission through the enactment of a unilateral, current minimum tax on the "global intangible low-taxed income" (GILTI) of CFCs. The post-TCJA US international tax law generally imposes current US tax on CFC income subject to reductions for foreign income taxes paid or accrued. This US regime supports the continued existence of a corporate income tax and presents an opportunity to co-ordinate the details of corporate income tax systems globally. Similarity among systems, for instance with respect to rate, timing and base, would further strengthen the corporate income tax and perhaps support innovations such as formulary apportionment. US tax administrators, non-US governments and taxpayers will each play a role in negotiating the details of international corporate income tax law going forward and in determining whether and on what terms these details converge
Citation source
In: British tax review. - London. - (2019), no. 4 ; p. 512-536
http://library.link/vocab/creatorName
Morse, S.C
Geographic coverage
  • North America
  • International
Language note
English
http://library.link/vocab/subjectName
  • GILTI
  • TCJA
  • tax reform
  • CFC
  • parent company
  • foreign source income
  • minimum tax
  • MNE
  • tax rate
  • intangibles
Label
GILTI : the co-operative potential of a unilateral minimum tax
Instantiates
Publication
Label
GILTI : the co-operative potential of a unilateral minimum tax
Publication

Library Locations

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      52.3736660 4.9336932
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