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On May 28, 2021, the US Department of the Treasury (Treasury) released the Fiscal Year (FY) 2022 budget and Green Book, which provides detailed insights into the proposals of US President Joe Biden’s recently released American Jobs Plan and American Families Plan. This article summarizes the key proposals affecting businesses and provides further insight on planning considerations.
IN DEPTH
COUNTRY-BY-COUNTRY REGIME TO APPLY TO GILTI AND FOREIGN BRANCH INCOME
The current global intangible low-taxed income (GILTI) regime operates on a global blended basis such that excess taxes paid in high-tax jurisdictions may be used to offset residual US taxes on income earned in low-tax jurisdictions. The Green Book raises a concern that global blending incentivizes US companies that have operations in high-tax jurisdictions to invest in low-tax jurisdictions, and US companies that have operations in low-tax jurisdictions to inves