Should the OECD Accept GILTI as an Income Inclusion Rule?
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Should the OECD Accept GILTI as an Income Inclusion Rule?
By Reuven S. Avi-Yonah
Reuven S. Avi-Yonah explores the possible outcome if the OECD were to recognize the U.S. global intangible low-taxed income tax as a legitimate pillar 2 income inclusion rule.