KPMG's Chetan Vagholkar and Eric Horvitz summarize in this article, which appeared in Tax Notes International on September 30, 2019, some good, bad, and ugly results of making the global intangible low-taxed income (GILTI) high-tax exception (HTE) under the proposed GILTI regulations released by Treasury on June 21, 2019.
About the authors: Chetan Vagholkar is partner and Eric Horvitz is a senior manager with KPMG's Internatonal Tax practice in the firm's Houston office.