Page 306 - International Taxation IRS Training Guides

Outbound Transaction to Minimize ETR

and GILTI (Post-TCJA)
(Cont’d)

License of IP License of IP
Possible tax issues

Could potentially
blend this with
USP high-tax
income currently in
IP
through
GILTI basket
Goods Goods affirmative Subpart F planning?

engaging in this
• By
planning (separating
CFC1 CFC2
and then
(High Tax) (Low Tax) royalty

affirmative Subpart F
planning),
USP has
Goods Goods optimized its
tax position

and maximized FTC
utilization?
Customers Customers
• IP royalties
may also
produce FDII

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