Layla Asali Quoted on Previously Taxed Earnings and Profits in Bloomberg Law
"Dividend Payouts Trigger Second Tax on Gains Unless IRS Steps In"
Layla Asali was quoted on the need for IRS guidance regarding the rules for previously taxed earnings and profits (PTEP) and mid-year distributions of current-year global intangible low-taxed income (GILTI) or Subpart F income. Uncertainty in the existing rules may cause taxpayers to "wait till the end of the year to distribute PTEP, but that might be a business decision and you can't help when to distribute," Asali said. The treatment of these earnings has become a larger issue since the passage of the Tax Cuts and Jobs Act. "Rather than this being a lurking old issue that came up once in a blue moon, it now comes up more frequently," Asali said.