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American Rescue Plan state tax cuts treasury clarification on American Rescue Plan ban on state tax cuts. Treasury minimum tax on current minimum tax on foreign profits of U.S. companies

Two Years After Passage, Treasury Regulations for the Tax Cuts and Jobs Act Surpass 1,000 Pages

Treasury released final regulations on the base erosion and anti-abuse tax (BEAT), which is meant to dissuade firms from engaging in profit shifting abroad. Other high-profile releases from 2019 include final regulations guiding enforcement of Section 199A, commonly known as the pass-through deduction; final regulations on enforcing the new tax on global intangible low-tax income (GILTI); and final regulations on state-level workarounds to the $10,000 limit on the state and local tax deduction (SALT).

5 min read
OECD Secretariat Proposal, OECD Public Consultation Document, Unified Approach under pillar one

What’s up with Being GILTI?

The Tax Cuts and Jobs Act made significant changes to the way U.S. multinationals’ foreign profits are taxed. GILTI, or “Global Intangible Low Tax Income,” was introduced as an outbound anti-base erosion provision.

5 min read