The Organization for Economic Co-operation and Development (OECD) is working with the U.S. Treasury Dept. to release guidance on its global minimum tax regime. The guidance will address the treatment of global intangible low-taxed income (GILTI) and certain tax credits. As the OECD’s second “pillar” of its Global Anti-Base Erosion Rules, which imposes a 15% global minimum tax, progresses toward fruition, concerns have been raised about how current U.S. tax law may conflict. This is despite the Biden administration’s hopes of conforming with the international tax framework. At issue is how the global minimum tax interacts with GILTI, established in 2017 by the Tax Cuts and Jobs Act.
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