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U.S. Joint Committee on Taxation Publishes Overview of the Taxation of GILTI and FDII

13 June 2019

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Approved Changes

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United States

The U.S. Joint Committee on Taxation has published an Overview of the Taxation of Global Intangible Low-Taxed Income (GILTI) and Foreign-Derived Intangible Income (FDII) Sections 250 and 951A. The overview documentation provides general information on the GILTI and FDII provisions, as all as a background on prior law and changes from prior law to present law. The over also provides specific information with respect to: GILTI, including: GILTI: Formula; Subpart F vs. GILTI; Gross Tested Income; Tested Income and Tested Loss; Net CFC Tested Income: Definition; Qualified Business Asset Investment; Net Deemed Tangible Income Return; GILTI Inclusion; GILTI and Section...