[20211109]IF11943_吉尔蒂：全球无形低税收入税收的拟议变化.pdf

https:/crsreports.congress.gov Updated November 9, 2021GILTI: Proposed Changes in the Taxation of Global Intangible Low-Taxed IncomeThe treatment of income earned abroad in U.S.-controlled foreign corporations (CFCs) has been extensively debated over the years. In the 2017 Tax Cuts and Jobs Act (P.L. 115-97), the tax treatment of foreign source income was altered. The prior system imposed taxes on CFCs income only when they paid dividends to their U.S. owners. The system taxed in full income earned in branches and certain types of easily shifted income of CFCs, referred to as Subpart F income. CFCs are foreign incorporated firms at least 50% owned by U.S. shareholders who hold at least 10% of the share by value or vote. Current Treatment The Tax Cuts and Jobs Act eliminated the tax on dividends and instead imposed a lower tax on CFCs aimed at intangible income, the tax on global intangible low-taxed income, or GILTI. GILTI targeted intangible income due to concerns about profit shifting (i.e., moving income to low-tax countries), because intellectual property is more easily moved than tangible property. In calculating income for GILTI, CFCs are allowed two deductions. One is a dee