Publication: Why R&D Should Be Allocated To Subpart F and GILTI
No Thumbnail Available
Open/View Files
Date
2020-06-23
Published Version
Published Version
Journal Title
Journal ISSN
Volume Title
Publisher
Tax Analysts
The Harvard community has made this article openly available. Please share how this access benefits you.
Citation
Stephen E. Shay, Reuven S. Avi-Yonah, Patrick Driessen, J. Clifton Fleming Jr. & Robert J. Peroni, Why R&D Should Be Allocated
To Subpart F and GILTI, 167 Tax Notes Fed. 2081 (2020).
Research Data
Abstract
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.
Description
Other Available Sources
Keywords
Terms of Use
This article is made available under the terms and conditions applicable to Other Posted Material (LAA), as set forth at Terms of Service