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Law360 Quotes Elizabeth Stevens on GILTI

July 10, 2019, Law360

A proposed high-tax exception to the 2017 tax law's global minimum tax could be a huge relief for those with self-owned businesses, whose income from directly held foreign subsidiaries otherwise faces an unforgiving system.

. . .

“If you make the election, as long as the income is taxed at 19%, you could have indefinite deferral,” said Elizabeth Stevens, an Associate with Caplin & Drysdale. “That's a pretty good deal.”

 . . .

The GILTI high-tax exception may not have been designed for them either, but they could stand to benefit greatly.

“You get the sense that they just kind of forgot that individuals have CFCs,” or controlled foreign corporations, Stevens said. “Individuals took a pretty hard hit under the TCJA. Maybe this brings that back into balance.”

 . . .

“Making the election to exclude high-tax income from GILTI could produce a more certain result than a 962 election,” said Stevens at Caplin & Drysdale.

For the full article, please visit Law360’s website (subscription required).

Excerpt taken from the article “Treasury's Global Tax Relief Offers Individuals Welcome Help” by Alex Parker for Law360 Tax Authority.


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