Perceived GILTI Shortcomings Focus of Senate Hearing

By: Andrew Velarde

The global intangible low-taxed income provision was a primary target of criticism from Democrats and witnesses at a Senate Finance Committee hearing, although most critiques focused on reforming GILTI rather than advocating a complete rewrite. The criticism at the March 25 hearing appeared to coalesce around three aspects of GILTI — its exemption from tax for qualified business asset investment income, its reduced rate, and its inapplicability on a per-country basis. These critiques come as Finance Committee Chair Ron Wyden, D-Ore., announced that he will release a new international tax framework “in the coming days” in cooperation with committee members Sherrod Brown, D-Ohio, and Mark R. Warner, D-Va.

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By Andrew Velarde, posted on Friday March 26, 2021
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