Page 192 - International Taxation IRS Training Guides

GILTI

tax years of foreign corporations beginning after
 Effective for
tax years of US shareholders in which
Dec. 31, 2017, and for

with which such tax years of foreign corporations end
or

with
 Regulations include anti-abuse rules for taxpayers
fiscal year-end CFCs
that entered into transactions or

arrangements
with other CFCs, before GILTI applied, that

would have allowed them

- to transfer assets, including intangible assets like intellectual property,

to a related party without having to include in tested income any gains
realized and
- to create basis
that the taxpayer would then depreciate or amortize (the
would use these deductions to reduce tested income, or
taxpayer
create or increase a tested loss).

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