Why R&D Should Be Allocated To Subpart F and GILTI
167 Tax Notes Fed. 2081 (2020)
20 Pages Posted: 13 Jul 2020 Last revised: 9 Jun 2021
Date Written: June 23, 2020
In this article, the authors critically appraise the government’s proposal not to allocate research and development deductions to subpart F inclusions and global intangible low-taxed income for foreign tax credit limitation purposes. They say the proposal is an unprecedented interpretation of the statute unsupported by any relevant legislative history that would radically change an R&D allocation method in place since 1977. They argue that the justifications provided in the proposed regulations’ preamble do not stand up to scrutiny.
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