Bryan Kelly will present "Proposed GILTI Regulations And Other International Tax Reform Issues" for the Beverly Hills Bar Association on October 31, 2018.
On September 13, 2018, the Internal Revenue Service issued proposed regulations concerning the application of the global intangible low-taxed income (GILTI) provisions of the Internal Revenue Code, generally effective for U.S. taxpayers with overseas operations beginning in 2018. GILTI, enacted as part of the Tax Cuts and Jobs Act on December 22, 2017, severely limits the ability of U.S. taxpayers to defer U.S. taxation of earnings of their foreign subsidiaries. The proposed regulations provide critical guidance on key elements of the GILTI calculations including "tested income", "tested loss", "qualified business asset investment" (QBAI) and "specified interest expense." This regulation package also includes guidance on the GILTI inclusion for domestic partnerships, anti-abuse rules and new reporting requirements, including the use of the new Form 8992 and a new schedule to Form 5471.
The panel of experienced international tax practitioners will provide an analysis of the regulations and will work through a few practical examples.