Few Answers On State Taxing Of Individuals’ GILTI Inclusions

By Peter Baum and Christopher Migliaccio

Article excerpt:

With the end of 2019 tax filing season, all calendar-year taxpayers have finally filed their first returns reporting Global Intangible Low Taxed Income inclusions. GILTI, enacted as part of the Tax Cuts & Jobs Act,affects all U.S. taxpayers who are U.S. shareholders of controlled foreign corporations.

While the name would suggest it targets income from intangibles located in low-taxed jurisdictions, GILTI actually functions as a minimum tax on foreign earnings of U.S. shareholders, with a reduction for returns on tangible assets and a limited high-tax exception only existing in proposed regulations at the moment.

This article was featured on Law360.

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