The Quasi-Global GILTI Tax

28 Pages Posted: 8 Jun 2021

See all articles by Susan C. Morse

Susan C. Morse

University of Texas at Austin - School of Law

Date Written: June 7, 2021


The U.S. minimum tax on global intangible low-taxed income, or GILTI, suggests a broad way of thinking about the corporate income tax. GILTI is not confined to a narrow view of a corporate tax as a national tax. Instead it rests on a global, or at least quasi-global, foundation. A foreign tax credit mechanism allows other jurisdictions to collect tax on GILTI, instead of only allowing GILTI taxes to support the U.S.fisc. Also, Treasury guidance has narrowed U.S. claims to GILTI tax revenue. As both of these features suggest, the function of the GILTI corporate tax is not limited to collecting U.S. tax revenue. Instead, GILTI is set up to support goals such as regulation, redistribution and efficiency on a global as well as national scale.

Keywords: GILTI, GloBE, minimum tax, global minimum tax

JEL Classification: K34, H20, H22, H25, H87

Suggested Citation

Morse, Susan C., The Quasi-Global GILTI Tax (June 7, 2021). Pittsburgh Tax Review, Vol. 18, No. 2, 2021, U of Texas Law, Public Law Research Paper , Available at SSRN:

Susan C. Morse (Contact Author)

University of Texas at Austin - School of Law ( email )

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Austin, TX 78705
United States

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