Proposed GILTI Regs Could Result in Taxable Phantom Income


Timothy Shuman and David Noren said that proposed regulations’ application of global intangible low-taxed income on a consolidated group basis was expected and helpful. “You can imagine traps for the unwary that would hurt taxpayers if they didn’t do that,” Mr. Noren said. “You could also imagine games the taxpayer could play by planning around which U.S. companies in a group hold which CFCs. It’s a simple and sensible result.”