Elizabeth Stevens Comments on Proposed Changes to GILTI Tax in Law360


A proposal from Senate Democrats to use existing U.S. Treasury regulations to enhance the tax on global intangible low-taxed income could reduce administrative complexity, but likely won't avoid all potential compliance and enforcement headaches with the proposal.

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"I think transfer pricing is an issue for either of these options for implementing country-by-country GILTI," said Elizabeth Stevens of Caplin & Drysdale. "It's probably more significant for the high-tax exclusion option, because you'll have a cliff effect at the threshold between high tax and low tax."

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