International Tax Draft Offers New Details, But Major Gaps Remain
Tax attorney Joshua Odintz was quoted in Tax Notes about the interaction between Global Intangible Low-Tax Income (GILTI) and the Organisation for Economic Co-operation and Development's (OECD) two-pillar plan in the latest draft proposal from the Senate Finance Committee Democrats. The draft bill, released on August 25, expands on the international tax framework outlined in April. The latest draft describes significant changes to international tax provisions but leaves key questions unanswered. Mr. Odintz noted that language in the discussion draft appears to address sandwich structures — that is, foreign parents with a U.S. corporation owning foreign subsidiaries.
"Practitioners have been discussing how to rationalize the two categories of foreign income and their differences. The potential haircut on subpart F foreign tax credits is concerning because it could increase the tax rate on subpart F income to greater than the U.S. corporate income tax rate."
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