... a shift from U.S. tax deferral to U.S. tax exemption of foreign profits, which increases the potential benefit to shifting U.S. income to low-tax foreign jurisdictions. To limit this potential income shifting, Congress enacted new rules, known as GILTI, to supplement the already existing Subpart F rules...

...Irwin J. (Jay) Katz ABSTRACT Subpart F of the Internal Revenue Code is a body of anti-abuse provisions designed to prevent U.S. shareholders from avoiding tax on the earnings (Subpart F income) generated by foreign corporations they control. Overall, its provisions lack the tax principle...