GILTI

[This is a guest post by Ed McClellan and Thomas Reilly that was originally published on June 2, 2021, in Covington’s Global Policy Watch Blog.]

 In mid-May, the Biden Administration officially threw its support behind a minimum global corporate income tax rate of at least 15%.  The U.S. proposal would be limited to the world’s 100 largest companies – those with revenues of over $20 billion.  The proposal would not depend on the company’s nationality (the U.S. has made clear that it would not support any proposals that discriminate against U.S. multinationals) and, since it would apply to digital services companies as well as to those selling tangible goods, would not be specific to any one sector.
Continue Reading A Proposed Global Minimum Corporate Income Tax Rate

Treasury Assistant Secretary for Tax Policy David Kautter attended the AICPA National Tax Conference on November 13, 2019, and commented that significant TCJA-related guidance should be expected to be released before the end of 2019.  Such guidance is likely to include proposed regulations addressing (1) federal income tax withholding under section 3402, (2) the executive compensation deduction limitation under section 162(m), and (3) computation of unrelated business taxable income (UBTI) under section 512. 
Continue Reading Significant TCJA Guidance Due Before End of Year, Kautter Says