July 2019

ACT Statement on Multi-Trade Association GILTI Expense Allocation Letter to Treasury Secretary Mnuchin

“As the name suggests, Congress intended the tax on Global Intangible Low-Taxed Income (GILTI) only to apply to foreign income that is taxed at very low rates in the foreign countries where it is earned.  The regulations issued to date, while certainly welcome and helpful to some companies, will subject many U.S. companies to the new GILTI tax even when their foreign income is not low-taxed.  To the extent the regulations require U.S. companies to pay U.S. tax on foreign income that has already been subject to high foreign taxes, U.S. companies will be less competitive in global markets, resulting in less investment in the United States and a loss of U.S. jobs. That’s why ACT has joined with six major national trade associations to ask the Secretary to issue additional expense allocation regulations that make the new tax law work as Congress intended.”

Trade Association Letter to Treasury Secretary Mnuchin regarding GILTI Expense Allocation (July 23, 2019)