Wednesday, March 07, 2018

GILTI versus FILTHI

I am currently rushing to complete a particular section of the article I'm in the middle of writing on the new international tax rules from the 2017 act, before heading out tomorrow (weather permitting) for an all too short vacation respite during part of our spring break.

If nothing else, the two particular rules that I've been writing about so far are cleverly named - BEAT (for "base  anti-erosion tax") and GILTI (for "global intangible low-taxed income").  Less so for the third that I'll get to later this month, FDII (for "foreign-derived intangible income").

Tax article writers have already been having much fun in their titles with both names.  E.g., "Get With the BEAT," "More GILTI Than You Thought," and "Guilty as Charged."

By contrast, my current article title is "Does the United States Now Have a 'Territorial' Tax System?" I answer this question "NO" by the top of page 2, and then get on with the rest of it.

But I couldn't help thinking of how GILTI might be renamed, without any loss of acroynmic punch. Suppose it were called "Foreign Intangible Low-taxed or Tax Haven Income." This would support using the acronym FILTHI.

20 comments:

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AZRA ISHAQUE said...

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Age: One Year, One Day
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AZRA ISHAQUE said...

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We deliver with time and precision as sethforth in the agreement. Our terms and Conditions are reasonable, below is our instrument description.

The procedure is very simple; the instrument will be reserved on euro clear to be verified by your bank, after verification an arrangement will be made for necessary bank documents and stock testing expenses, the cost of the Bank Guarantee will be paid after the delivery of the MT760.

DESCRIPTION OF INSTRUMENT:
Instrument: Bank Guarantee (BG/SBLC).
Total Face Value: Minimum of 1M Eur/USD (One Million Eur/USD) to Maximum of 5B Euro/USD(Five Billion Eur/USD).
Issuing Bank: HSBC London, Barclays Bank, Deutsche Bank Frankfurt, Hong Kong, Any AA rated Bank in Europe or any Top 25 WEB.
Age: One Year, One Day
Leasing Price: 4% of Face Value plus 1% commission fees to brokers.
Delivery: Bank to Bank SWIFT.
Payment: MT-760.
Hard Copy: Bonded Courier within 7 banking days.

All relevant business information will be provided upon request plus our terms and
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7. Subsequent tranches: To be mutually agreed between both parties

8. Issuing Bank: Top RATED world banks like HSBC, Barclays, ING Dutch Bank, Llyods e.t.c

9. Delivery Term: Pre advise MT199 or MT799 first. Followed By SWIFT MT760

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collateral with any bank in the world
to secure loans for your project or to
activate credit line to finance your
business plan. We have {BG}, Standby
Letter of Credit {SBLC}, Medium Term
Notes {MTN}, Confirmable Bank Draft
{CBD} as well as other financial
instruments issued from AAA Rated bank
such as HSBC Bank Hong Kong, HSBC Bank
London, Deutsche Bank AG Frankfurt,
Barclays Bank , Standard Chartered Bank
and others on lease at the lowest
available rates depending on the face
value of the instrument needed.


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Skype : nat.mandate18@gmail.com


Regards
Nat

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Keat Cheng said...

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we always deliver on time and precision as Set forth in the agreement. You are at liberty to engage our leased facilities into trade programs, project financing, Credit line enhancement, Corporate Loans (Business Start-up Loans or Business Expansion Loans), Equipment Procurement Loans (Industrial Equipment, Air crafts, Ships, etc.) as well as other financial instruments issued from AAA Rated bank such as HSBC Bank Hong Kong, HSBC Bank London, Deutsche Bank AG Frankfurt, Barclays Bank , Standard Chartered Bank and others on lease at the lowest available rates depending on the face value of the instrument needed, Our Terms and Conditions are reasonable.
DESCRIPTION OF INSTRUMENTS:
1. Instrument: Bank Guarantee (BG)/SBLC (Appendix A)
2. Total Face Value: 10M MIN to 50B MAX USD or Euro
3. Issuing Bank: HSBC, Deutsche Bank Frankfurt, UBS or any Top 25 .
4. Age: One Year, One Day
5. Leasing Price: 4+ 1%
6. Sale Price: 32+2%
7. Delivery by SWIFT .
8. Payment: MT103-23
9. Hard Copy: Bonded Courier within 7 banking days.
If you have need for Corporate loans, International project funding, etc. or if you have a client that requires funding for his project or business, We are also affiliated with lenders who specialize on funding against financial instruments, such as BG, SBLC, POF or MTN, we fund 100% of the face value of the financial instrument.
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cornelius nysschens said...

Dear sir/ma
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Regards
cornelius

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Muhammed Emir Harun said...


We Facilitate Bank instruments SBLC for Lease and Purchase. Whether you are a new startup, medium or large establishment that needs a financial solution to fund/get your project off the ground or business looking for extra capital to expand your operation,our company renders credible and trusted bank guarantee provider who are willing to fund and give financing solutions that suits your specific business needs.

We help you secure and issue sblc and bank guarantee for your trade, projects and investment from top AA rated world Banks like HSBC, Barclays, Dutch Ing Bank, Llyods e.t.c because that’s the best and safest strategy for our clients.e.t.c

DESCRIPTION OF INSTRUMENTS

1. Instrument: Funds backed Bank Guarantee(BG) ICC-600

2. Currency : USD/EURO

3. Age of Issue: Fresh Cut

4. Term: One year and One day

5. Contract Amount: United State Dollars/Euros (Buyers Face Value)

6. Price : Buy:32%+1, Lease: 4%+2

7. Subsequent tranches: To be mutually agreed between both parties

8. Issuing Bank: Top RATED world banks like HSBC, Barclays, ING Dutch Bank, Llyods e.t.c

9. Delivery Term: Pre advise MT199 or MT799 first. Followed By SWIFT MT760

10. Payment Term: MT799 & Settlement via MT103

11. Hard Copy: By Bank Bonded Courier


Interested Agents,Brokers, Investors and Individual proposing international project funding should contact us for directives.We will be glad to share our working procedures with you upon request.



Name: Muhammed Emir Harun

Contact Mail :info.financewizardltd@gmail.com

Skype: info.financewizardltd@gmail.com

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