Page 305 - International Taxation IRS Training Guides
P. 305
Outbound Transaction Example and
GILTI (Post-TCJA) (Cont’d)
Possible tax issues
License of IP License of IP
• USP
could be in
USP IP situation where
excess FTCs are
permanently
lost.
Goods Goods
What can it do?
• Separate price of
from the
CFC1 CFC2 intangibles
(High Tax) (Low Tax) sale of goods
create
− May
Goods Goods significant low-
tax, foreign-
source, general
Customers Customers basket income.
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