Miles Humphrey and Mark Saunderson (Deloitte) review the new areas of global intangible low taxed income and foreign derived intangible income.
US tax reform fundamentally reshaped the way in which the US taxes numerous areas. In our previous article (‘US tax reform: practical aspects’ Tax Journal 15 June 2018) we wrote about the impact of three of the major changes that were introduced: the new base erosion and anti-abuse tax (BEAT); the enhanced interest deductibility restrictions; and the introduction of hybrid rules.
We did not examine the new global intangible low taxed income (GILTI) provisions as their scale requires a detailed discussion. We are therefore devoting this article to GILTI together with the closely-related provisions on foreign derived intangible income (FDII).
This article will be relevant both to US companies with UK operations and to UK companies with US operations.
The previous regime
...
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Miles Humphrey and Mark Saunderson (Deloitte) review the new areas of global intangible low taxed income and foreign derived intangible income.
US tax reform fundamentally reshaped the way in which the US taxes numerous areas. In our previous article (‘US tax reform: practical aspects’ Tax Journal 15 June 2018) we wrote about the impact of three of the major changes that were introduced: the new base erosion and anti-abuse tax (BEAT); the enhanced interest deductibility restrictions; and the introduction of hybrid rules.
We did not examine the new global intangible low taxed income (GILTI) provisions as their scale requires a detailed discussion. We are therefore devoting this article to GILTI together with the closely-related provisions on foreign derived intangible income (FDII).
This article will be relevant both to US companies with UK operations and to UK companies with US operations.
The previous regime
...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
