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United States | Senate Finance Committee version of tax reconciliation bill adds new international proposals, modifies other proposals in House-passed bill

|Tax Alerts, Information Reporting, Asset ...|United States
United States

  • The Senate Finance Committee budget reconciliation bill (the Senate Bill) would significantly change the international provisions of the Code and impact both outbound and inbound taxpayers.
  • The Senate Bill would modify the regimes for global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII) by reducing expense apportionment and increasing the effective federal tax rate on GILTI and FDII.
  • The Senate Bill would also significantly modify the rules for the beat erosion a…

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