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Extract to table / gilti-beat-impact-analysis.docx
gilti-beat-impact-analysis.docx
Parties
Penterra Pharmaceuticals Corp
Global Intangible Low-Taxed Inc
Penterra Manufacturing Ireland Ltd
Associates LLP
Net CFC Tested Inc
Net Deemed Tangible Inc
Tested Inc
GILTI Inc
Dates
October 14, 2022
January 1, 2018
December 31, 2020
July 1, 2012
December 31, 2017
January 1, 2026
December 31, 2025
August 3, 2022
December 22, 2017
January 1, 2017
Amounts
$380.4
$235.01
$188.04
$42.65
$15.98
$312
€2.14
€1.06
€47.2
$57.61
Obligations
Under the GILTI regime, a United States shareholder of a CFC must include in gross income its pro rata share of the CFC's "global intangible low-taxed income
The composition of PBI's income between KDB-qualifying and non-qualifying income is therefore a critical variable in the quantitative model and must be obtained from PBI's Irish tax computations and from Thornbury & Keogh
The analysis must examine each category of intercompany payment flowing from PPC to its related foreign entities
Higher regular tax (from GILTI inclusions) raises the floor that BEAT must exceed
The Irish-side implications of the proposed § 482 adjustments must be coordinated with PBI's Irish tax advisors, Ciarán Thornbury and his team at Thornbury & Keogh, Chartered Tax Advisors, Dublin