REG

Question 1

What is global intangible low-taxed income (GILTI)?

Answer 1

Approximate income earned by foreign affiliates of US companies from foreign-held intangible assets (patients, trademark or copyrights).

Design to prevent companies from shifting their profits to foreign countries with lower tax rates.

GILTI is taxed at a low rate immediately rather than being deferred and taxed at a higher rate.

Question 2

What is the tax treatment of qualified small business stock (QSBS)?

Answer 2

Noncorporate taxpayers are permitted to exclude all or part of a gain realized on the sale of a QSBS if the stock is owned at least 5 years prior to the sale.

But exclusion is subject to a ceiling of the greater of

• 10 times stock basis
• $10,000,000 (reduce by any previous exclusions on the stock)