GHJ Tax Partner Polina Chapiro spoke at a Beverly Hills Bar Association event discussing proposed GILTI regulations and other international tax reform issues October 31, 2018. The Internal Revenue Service issued proposed regulations concerning the application of the global intangible low-taxed income (GILTI) provisions of the Internal Revenue Code, generally effective for U.S. taxpayers with overseas operations beginning in 2018. GILTI, enacted as part of the Tax Cuts and Jobs Act, severely limits the ability of U.S. taxpayers to defer U.S. taxation of earnings of their foreign subsidiaries. The proposed regs provide critical guidance on key elements of the GILTI calculations including "tested income", "tested loss", "qualified business asset investment" (QBAI) and "specified interest expense." This reg package also includes guidance on the GILTI inclusion for domestic partnerships, anti-abuse rules and new reporting requirements, including the use of the new Form 8992 and a new schedule to Form 5471. The panel of experienced international tax practitioners will provide an analysis of the regs and will work through a few practical examples.

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