Layla Asali Comments on GILTI Regulations in Law360 Tax Authority

"Closing Gaps in GILTI Opens Up Authority Questions"

Law360 Tax Authority


Layla Asali commented on recent regulations released by the U.S. Department of the Treasury providing guidance on the Tax Cuts and Jobs Act's (TCJA's) Global Intangible Low-Taxed Income (GILTI) provision. Asali addressed the high-tax exception in the new proposed GILTI regulations. "It's a very welcome step for companies, since over the past 18 months since the statute was enacted, the issue of high-tax GILTI income being potentially subject to residual U.S. tax has been a really difficult issue for certain U.S. companies," Asali said. "It's a good tax policy result."