According to an update from the U.S. Office of Information and Regulatory Affairs (OIRA), the proposed Global Intangible Low-Taxed Income (GILTI) Regulations were received on 22 August 2018 and are currently pending review. The inclusion of GILTI, which is a new category of CFC income for tax years beginning after 31 December 2017, was introduced by the Tax Cuts and Jobs Act. Broadly, GILTI is equal to the pro-rata share amount of net CFC tested income in excess of a benchmark return equal to 10% of the qualified business asset investment of all CFCs, less interest expense. Initially, a 50%...