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2022 72nd Midyear Conference

M07 - Planning for the Proposed Shift to Per-Country Application of GILTI and FTC Limitations

Mar 21, 2022 1:00pm ‐ Mar 21, 2022 2:00pm


This session will discuss how multinational enterprises should prepare to address the potential implementation of a per-country limit on foreign tax credits and GILTI. Both changes present planning opportunities and risks, as well as significant compliance issues.

Learning Objectives:
  • Understand the implications of per-country limits on the FTC and GILITI
  • Assess what advance planning opportunities and risks are or might be available to their company
  • Determine the compliance issues associated with FTC and GILTI limits with the greatest impact on their company.




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