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Legal Update

GILTI Pleasures: The IRS Releases Proposed Regulations on Global Intangible Low-Taxed Income

21 September 2018
Mayer Brown Legal Update
On September 13, 2018, the US Internal Revenue Service released the first set of proposed regulations addressing how to compute the new tax imposed on global intangible low-taxed income or “GILTI.” The GILTI rules were enacted in the Tax Cut and Jobs Act in December 2017, and GILTI is taxable beginning in 2018. GILTI is a newly designated type of income that is earned by controlled foreign corporations and is taxable to US shareholders. GILTI inclusions are not limited to passive income nor are they limited by the earnings and profits of the CFC. Mark Leeds and Lucas Giardelli of the New York office of Mayer Brown analyze the proposed regulations in the Legal Update “GILTI Pleasures.”


  • Mark H. Leeds
    T +1 212 506 2499
  • Lucas Giardelli
    T +1 212 506 2238

Related People

  • Brian W. Kittle
    T +1 212 506 2187
  • Gary Wilcox
    T +1 202 263 3399
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