The new US GILTI tax regime has led some to qualify the new US TCJA system as a quasi-territorial tax system .
The new US GILTI tax regime acts like an international alternative minimum tax for IP - heavy US multinationals .
The new US GILTI tax regime , which acts like an international alternative minimum tax for IP - heavy US multinationals , has led some to qualify the new US TCJA system as a quasi-territorial tax system .