Henry Stow Lovejoy moderated and participated in the panel titled "Banks And The International Provisions Of The Tax Cut And Jobs Act" at the ABA Section of Taxation 2018 Fall Tax Meeting

The panel discussed the effect of amended subpart F rules, global intangible low-taxed income (“GILTI”) inclusion, and the base erosion and anti-abuse tax (“BEAT”) on domestic and foreign banks. 

Subjects included downward attribution, allocation of expenses and its effect on GILTI foreign tax credits, and financing of US banks by foreign affiliates. Current and potential future IRS and Treasury guidance were also considered.