Apr 02, 2019 03:00
The 2017 tax reform legislation generally retained the existing subpart F rules that apply to passive and “mobile” income, but created a new, broad class of income—“global intangible low-taxed income” (GILTI) that is subject to immediate U.S. taxation. The U.S. Treasury and IRS released proposed GILTI regulations on September 13, 2018. In conjunction with the proposed regulations, the IRS released two draft forms: Form 8992—Global Intangible Low-Taxed Income (GILTI) and Form 8993—Section 250 Deductions for Foreign Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI).
The proposed GILTI regulations significantly expand on the statutory framework with detailed guidance and clarifications on a number of GILTI implementation issues. KPMG LLP (KPMG) is pleased to invite you to a TaxWatch Webcast that will discuss the potential implications of the proposed GILTI regulations. Professionals from KPMG’s Washington National Tax practice, including Ron Dabrowski, Seth Green, and Barbara Rasch, will discuss: