Jun 25 2019 37 mins 1
Doug McHoney (PwC's International Tax Services Leader) interviews Elizabeth Nelson (International Tax Services Partner) and Aaron Junge (International Tax Services Director) about the final and newly proposed GILTI regulations. Elizabeth and Aaron walk through the key changes in the regulations, including, narrowing the scope of the pro rata share anti-abuse rule, the aggregate treatment of US partnerships, the broader basis step up anti-abuse rules, the reservation on basis adjustment rules for tested loss, the legal and retroactive effect of regulations, and the high tax exception.
