Law360 Quotes Clark Armitage on GILTI Glitch
Treasury announced it will smooth over a potential glitch in how its global intangible low-taxed income (GILTI) rules calculate foreign income, but it remains to be seen whether the planned fix indicates a more flexible approach on the calculation of foreign tax credits.
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"In every other situation, you would associate the taxes paid on a particular item of income with that item of income," said Clark Armitage of Caplin & Drysdale, Chtd.
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Excerpt taken from the article “GILTI Glitch Smoothed Over, Foreign Tax Puzzle Unclear” by Alex M. Parker for Law360.