8月, the Senate Finance Committee released draft legislation that would overhaul the international provisions of the 税 Cuts and Jobs ACT (TCJA). Included in these changes are alterations of the GILTI regime.
由2017 TCJA推出, Global 包容 of Low-税 Income (“GILTI”) is a category of income earned abroad by U.美国控制的外国公司(CFCs). GILTI was instituted to discourage the shifting of profits from the US to foreign subsidiaries’, which was then only 税able if the earnings were repatriated as dividends.
A U.S shareholder’s GILTI inclusion is generally defined as the excess of a US 分享holder’s aggregated “net tested income” over its net deemed tangible income return (“net DTIR”). 虽然这个计算可能很复杂, for simplicity’s sake “tested income” is the corporation’s gross income less certain deductions, including income effectively connected with a US trade or business, F分项收入, 有关人士收到的股息, 还有一些外国石油 & 天然气的收入. Net DTIR is the excess of 10% of the aggregate of the U.S. 分享holder’s pro-rata share of Qualified Business Asset Investment (QBAI), which is essentially the bases of items held abroad including buildings, 机械, 或设备.
The draft legislation would change the structure of GILTI in a few key ways. First, it would eliminate DTIR and QBAI from the GILTI calculation itself. US 分享holders would include in gross income their net CFC tested income, 而不是目前计算的GILTI. The elimination of QBAI would likely discourage 税payers from owning depreciable assets abroad.
第二个, GILTI would be calculated on a country-by-country bases, meaning losses incurred in one country would no longer offset income earned in another. This could be bad news for 税payers with CFCs in multiple countries. This change would also limit the application of the Foreign 税 Credit for many 税payers, 哪个目前与GILTI协同工作.
For more information on how these changes may impact you, please reach out to your 施耐德唐斯税 咨询或bet9平台游戏 (电子邮件保护).
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