By Kate Davidson and Richard Rubin 

WASHINGTON -- U.S.-based multinationals will be less exposed to certain U.S. taxes after the Treasury Department issued new rules implementing two major pieces of the 2017 tax law.

The regulations, unveiled on Monday, will help ease the burden of two separate minimum taxes that were designed to put a floor under corporate tax collections.

Senior Treasury officials said rules largely finalize regulations proposed late last year, while also addressing U.S. multinational firms' concerns.

One minimum tax affected by the regulations is the Global Intangible Low-Taxed Income Tax, or GILTI, which was projected to raise $112 billion over a decade.

The rule includes a provision that would allow companies to treat certain assets as 50% exempt for expense allocation purposes under GILTI, a senior Treasury official said.

Treasury officials also proposed more generous rules for calculating the foreign tax credit, including changes to the allocation and apportionment of research and experimental tax deductions. The Treasury official said the change will generally allow those subject to the GILTI tax to increase their use of foreign tax credits.

The second minimum tax is known as the Base Erosion and Anti-Abuse Tax, or BEAT. Congress wrote the BEAT to make it harder for companies to load up their U.S. operations with deductions and push profits to related entities abroad.

Write to Kate Davidson at and Richard Rubin at


(END) Dow Jones Newswires

December 02, 2019 17:22 ET (22:22 GMT)

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