Bloomberg Tax: Tax Executives Fear Overhaul Impermanence as Dems Mull Tweaks

The GILTI income subject to the tax is the income earned through a controlled foreign corporation that exceeds 10 percent of the value of the CFC’s tangible, depreciable assets, such as machinery and other equipment.

The Institute on Taxation and Economic Policy, a Washington think tank, said in a June 2018 post that this measurement actually encourages companies to move their tangible assets offshore, and pointed out that multinationals can use foreign tax credits generated from foreign taxes they have previously paid to further reduce their GILTI hit. Read more