Overview
Law360 quoted George Callas in an April 22 article titled "US Debate on Fighting Income-Shifting Could Return at OECD." The article discusses a foreign provision of the 2017 US Tax Cuts and Jobs Act (TCJA) designed to fight income-shifting. The TCJA's tax on global intangible low-taxed income (GILTI) is meant to work as a backstop to prevent companies from shifting their income offshore while the law overall exempts foreign income. The debate over income-shifting is returning to the international stage as the Organization for Economic Cooperation and Development (OECD) considers a similar tax.
Callas, former senior tax counsel to then House Speaker Paul Ryan and former chief tax counsel to the House Ways and Means Committee, tells Law360 that a country-by-country GILTI would be "incredibly onerous." Callas says: "The question becomes, what are you achieving through this huge administrative burden? We thought it was not Congress' job to put American companies at a disadvantage around the world to protect foreign tax bases."
The full article can be read at Law360 (subscription required).