Our second and most significant permanent GILTI relief BY FAR!!!
Our first GILTI win provided a way for businesses to avoid GILTI tax (and double taxation) so long as the business was located in a country where the corporate tax rates were higher than 13%. However, high annual GILTI compliance meant that we had to pay a fortune in GILTI compliance costs even though no GILTI tax was due. See March 5, 2019 post titled Treasury grants businesses GILTI fix.
This win goes much farther. So long as the business is subject to corporate tax of 18.9% in the country where the business is located, NOannual compliance is required at all. This is exactly what the Israeli Ministry of Finance proposed!!! See previous post.
Of course, if your business is in a country with lower than 18.9% corporate tax rates, then the first fix (13%) applies, but annual compliance is needed. Also, if your business has income that is taxed at below this rate, it is subject to GILTI. So we will fight Treasury to get 100% exemption from GILTI in ALL cases.
However, this is a major win!!! To see the rather technical language of the fix, click below. You should consult with your US tax professional on this matter.
https://drive.google.com/file/d/1euuqH__sArmzzfBqa54_QGE-1Jc_qBrL/view?usp=sharing
