The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
By: Reuven S. Avi-Yonah
At first glance, the question in the headline may appear to be frivolous. The global intangible low-taxed income regime must be constitutional — GILTI builds on subpart F, which built on the foreign personal holding company (FPHC) regime that was declared to be constitutional in Eder back in 1943. But perhaps it isn’t that easy.
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