Tony Billings accepted for publication in Tax Notes International

Mike Ilitch School of Business Professor of Accounting Tony Billings has had an article accepted for publication in Tax Notes International, a weekly publication focused on international taxation.

The paper, titled “Differences in the Consequences of Global Intangible Low-Taxed Income and Subpart F Income Inclusions,” was co-authored by Ilitch Business graduate Stephanie Wu (M.S.A. ’21).


This paper discusses the application of the subpart F and Global Intangible Low-Taxed Income (GILTI) as the provisions apply to U.S. multinational corporations along with the challenges and confusion caused by these provisions. The U.S. Congress enacted the subpart F provisions as part of the Revenue Act of 1962. Under the subpart F regime, U.S. shareholders of controlled foreign corporations (hereafter CFC) are required to include the pro-rata share of the CFC’s subpart F income in gross income. The U.S. Congress followed up in 2017 with a new tax regime called GILTI. The GILTI regime aims to discourage U.S. companies from shifting profits to offshore low-tax jurisdictions. With respect to GILTI, Internal Revenue Code (hereafter IRC) Sections 951A and 952 require U.S. shareholders to include any GILTI and subpart F inclusion from a CFC as current year taxable income even though the subpart F inclusion is taken into income before GILTI is determined. Both the subpart F and GILTI require U.S. shareholders owning 10 percent or more of a CFC to classify specific streams of income as subpart F income or GILTI and include them in their U.S. gross income even though such income may not have been repatriated. The article explains that GILTI is generally a U.S. shareholder level computation and concept, whereas Subpart F is computed on a CFC by CFC income basis.

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