GILTI May Entice Low-Margin Businesses to Move Operations Abroad


David Noren told a DC Bar Association meeting that companies may not bring IP back into the United States since they might later lose the benefit from the new tax bill’s global intangible low-taxed income (GILTI) provision. “We seem to be on a path to veer wildly from different policy preferences, so you’d have to be pretty brave, if you had IP sitting safely outside the U.S., to bring it back in and trust that there’s not going to be a massive change in the law five years from now,“ Mr. Noren said.