Susan C. Morse, of the University of Texas at Austin – School of Law, has made available for download her article, “The Quasi-Global GILTI Tax”, published in the Pittsburgh Tax Review, volume 18. The abstract is as follows:
The U.S. minimum tax on global intangible low-taxed income, or GILTI, suggests a broad way of thinking about the corporate income tax. GILTI is not confined to a narrow view of a corporate tax as a national tax. Instead it rests on a global, or at least quasi-global, foundation. A foreign tax credit mechanism allows other jurisdictions to collect tax on GILTI, instead of only allowing GILTI taxes to support the U.S.fisc. Also, Treasury guidance has narrowed U.S. claims to GILTI tax revenue. As both of these features suggest, the function of the GILTI corporate tax is not limited to collecting U.S. tax revenue. Instead, GILTI is set up to support goals such as regulation, redistribution and efficiency on a global as well as national scale.
To see the full article, click: “The Quasi-Global GILTI Tax” by Susan C. Morse
Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.