This column describes new proposed Code Sec. 163(n) and the proposed general removal of expense allocation to GILTI in the Build Back Better Act (the “BBBA”). This column focuses on the version of the BBBA proposed on...more
Until recently, the high US corporate tax rate and regime governing interest deductibility had provided a clear incentive for multinationals (particularly, non-US multinationals) to push interest expense into the United...more