Yesterday, Treasury issues final regulations that exclude from the GILTI regime all corporate income which is taxed at least 18.9% in the country of residence. In essence it means this: if your company is subject to corporate tax of 18.9% on all its income, then none of that income is subject to GILTI. And since you have no GILTI income, YOU DO NOT HAVE TO COMPLY WITH GILTI AT ALL!!!!!
This is a major win for us, esp. since most of us live in high-tax countries. The win last week regarding the final regulation allowing us the 50% deduction was 100% the result of our efforts. In this week's case, this week's final regulation was pushed very hard by corporate America which greatly benefits from this reg. However, we were among the very first to request this, and actively pushed this. In fact, I met with the Israeli Finance Ministry and asked for this relief back in August 2018,
As a result, the Israeli Ministry got involved and formally requested this exact relief.
See the first paragraph of the executive summary of the letter Israel sent which specifically requests this exemption -