Jeffery M. Kadet and David L. Koontz, Transitioning from GILTI to FDII? Foreign Branch Income Issues, 164 Tax Notes Fed. 57 (2019), https://digitalcommons.law.uw.edu/faculty-articles/513
Tax Notes Federal
In this article, Kadet and Koontz explain the risks and benefits multinationals must consider in deciding whether to transition some operations conducted within a controlled foreign corporation (along with the associated income) into a domestic group member to achieve a structure that qualifies for foreign-derived intangible income.