Page 494 - Large Business IRS Training Guides

Real World Transfer
Pricing Impact of GILTI &

Intangible Property Related Changes 5

Impact of 2017 TCJA’s
Transfer Pricing

Intangible Property
GILTI Regime &

a Real World Case (Post-TCJA):
Changes on

• What might
be three primary tax minimization goals of
establishing this Intangible Property
migration structure?

• Second, minimize the US tax consequences that emanate from

the post transfer activity generated within the foreign structure.

f both Pricing and Non-pricing Related Changes.
• Impact o
Establishing
GILTI Structuring Techniques Intended to Minimize
the U.S.
Tax Capture of Foreign Generated Residual Returns
and Associated Foreign Tax Credit Benefits.

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