Ilitch School accounting professors to publish in reputable tax journal

Mike Ilitch School of Business accounting professors Tony Billings and Santanu Mitra had their paper titled “New Incentives for US corporations to Bring Intangible Property Home” accepted for publication in the June 2019 issue of Tax Notes. Tax Notes is a B journal, and the most widely read and cited tax journal in the United States.


This article updates Certified Public Accountants (CPAs) and other financial professionals about changes wrought by the Tax Cuts and Jobs Act of 2017 (TCJA) and the newly issued Treasury Regulations in helping their clients implement the new tax rules to maximize Foreign Derived Intangible Income (FDII) deductions associated with foreign-derived intangible income. The US Congress enacted significant reforms to the international tax system as part of the TCJA. As part of the reform, a shift was made from a worldwide system of taxation toward a hybrid territorial model of taxation. The new law substantially changed the way foreign profits of US-based corporations are taxed. Specifically, the new law addressed perceived concerns regarding US multinational corporations (MNCs) with foreign affiliates by including international provisions pertaining to Global Intangible Low-Taxed Income (GILTI) and Foreign Derived Intangible Income (FDII). The changes have resulted in significant confusion regarding how the new tax provisions should be applied and how the international tax law changes affect businesses.

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