The U.S. IRS has released an international practice unit on Concepts of Global Intangible Low-Taxed Income. The general overview of the practice unit includes the following: IRC 951A, which contains the global intangible low-taxed income ("GILTI") rules, was added to the Code by the Tax Cuts and Jobs Act ("TCJA"). A key feature of the TCJA was to provide corporate shareholders a 100% dividends received deduction ("DRD") on dividends from foreign corporations (assuming certain requirements are met), but the DRD could incentivize taxpayers to shift income offshore to low- or no-tax jurisdictions (e.g., mobile income from intangible property). To neutralize...