Page 403 - Large Business IRS Training Guides

Interaction with Other
International Provisions

on transfer pricing models:
Impact

• Pre-TCJA:

• Focus on supply
chain models that did not correlate with actual
flow
of product
of income and intangible assets
• Allocation and apportionment
to low- or no-tax jurisdictions
• Post-TCJA:

low- or no-tax jurisdictions now subject
• Intangible income from
to GILTI

certain transfers of property and provision
• Income derived from
services now eligible for FDII deduction
of
modeling and revisions in transfer
• Result: Taxpayer
pricing methodologies to minimize their global effective
tax rate

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