Six Main Areas Identified For TCJA International Guidance

In anticipation of tax reform 2.0, six major international areas have been identified as prime for regulatory focus and guidance: the allocation of expenses to GILTI income; the application of the accumulated earnings tax under section 531 to GILTI;  treatment of consolidated tax return filers for GILTI purposes; potential carve-outs to the base erosion and anti-abuse tax (or BEAT); the treatment of intercompany deductible payments for purposes of the BEAT;  and the effect of the repeal of section 958(b)(4) on the portfolio interest exemption from withholding.

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