The GILTI High-Tax Exception: Who Benefits?

By: Mindy Herzfeld

Mindy Herzfeld examines whether, in finalizing regulations implementing the subpart F high-tax exception to items of income that would otherwise be tested income taxable as global intangible low-taxed income, Treasury exceeded its statutory authority, subverted congressional intent, and provided a giveaway to corporate taxpayers.

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By Mindy Herzfeld, posted on Monday August 24, 2020

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