The GILTI High-Tax Exception

The Good, the Bad, and the Ugly

Proceed with caution, and do not underestimate the value of modeling the impact of the GILTE HTE.

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.