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Expert Analysis

Foreign Income Regs Provide Some Clarity But Issues Remain

By Robert Kiggins ( August 26, 2020, 1:43 PM EDT) -- Both global intangible low-taxed income, or GILTI, and foreign-derived intangible income, or FDII, are creatures of the Tax Cuts and Jobs Act enacted on Dec. 22, 2017. GILTI has been plagued with technical issues from the very start and FDII has been under criticism internationally as an illegal export incentive or harmful tax practice....

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