: Why offshore IP when there is subpart F income tax? After TCJA (Tax Cuts and Jobs Act), there is the not deferrable GILTI (Global Intangible Low Tax Income) tax which was supposed to deter US firms from offshoring their IP.

Vote Up Vote Down   0 Reactions

Login to give Reaction!

Why offshore IP when there is subpart F income tax?
After TCJA (Tax Cuts and Jobs Act), there is the not deferrable GILTI (Global Intangible Low Tax Income) tax which was supposed to deter US firms from offshoring their IP. However prior to TCJA, there was also the subpart F income tax which also tax royalties earned from IP.

So prior to TCJA, why did US firms still offshore thier IP? Wasn't subpart F income tax a deterrent?

(0)

Login to post a comment!