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.