Proposed GILTI Regs’ Anti-Abuse Rule Seen as Overly Broad


David Noren said that the anti-abuse provision in proposed regulations on global intangible low-taxed income could allow the Internal Revenue Service to disregard certain offshore transactions involving companies with non-calendar fiscal years. “For a certain subset of taxpayers with non-calendar fiscal years, that was sort of a surprisingly broad approach, and I think it’s going to lead to some controversy between the government and taxpayers and maybe even some challenges to the validity of the rule,” he said.