Closing Gaps in GILTI Opens Up Authority Questions


Steven Hadjilogiou commented on the recent regulations that include a new proposed rule creating a high-tax exception to the Tax Cuts and Jobs Act ‘s GILTI provision, as well as final rules for determining the GILTI tax liability for partnerships with interests in foreign entities. The exception “really was well-intentioned, but I don’t know that it’s going to have the impact or the benefit to the people or companies that needed it the most,” he said.