ITC - International Tax Calculator | Orbitax’s US International Outbound tax solution |
GTC - Global Tax Calculator | Orbitax’s integrated solution which combines the existing ITC with our new Global Minimum Tax Calculator |
E.A.T. - Executable Action Tool | Orbitax’s workflow solution which allows tax departments to create, share, and execute custom business processes based on conditional steps and actions. |
API - Application Programing Interface | Automated connection process which allows Orbitax solutions to connect to 3rd-party software in order to streamline tax calculation processes. |
IRC - Internal Revenue Code | References to “Section” are made to the United States Internal Revenue Code of 1986, as most recently amended. |
TCJA - Tax Cuts and Jobs Act | Congressional revenue act of the United States introduced in 2017 which amended the Internal Revenue Code and introduced significant changes to the United States tax system. |
CFC - Controlled Foreign Corporation | A foreign corporation which is controlled by a domestic corporation as defined under Section 957. |
BEAT - Base Erosion and Anti-Abuse Tax | Corporate minimum tax imposed under Section 59A related to certain base erosion payments to foreign related parties |
FDII - Foreign-Derived Intangible Income | Deemed excess domestic returns that are considered foreign-derived. Certain taxpayers are eligible for an additional deduction related to their FDII income under Section 250. |
GILTI - Global Intangible Low-Taxed Income | Income inclusion under Section 951A related to a type of income earned by CFCs and subject to a preferential tax rate through an additional deduction under Section 250. |
Subpart F | Type of income earned by a CFC, as defined under Section 952. This type of income gives rise to an income inclusion under Section 951. |
FTC -Foreign Tax Credit | Tax credit related to foreign income taxes paid which is used to offset domestic tax liability. |
E&P - Earnings and Profits | Measure of economic income of a corporation available for distribution to its shareholders. |
RP Interest - Related Party Interest | Interest paid to, or received from, a related party. |
FX Rates - Foreign Exchange Rates | Translation rates used to convert functional currency to reporting currency or vice versa. |
Int Exp Appt - Interest Expense Apportionment | Assigning interest expense to a category of income for purposes of Foreign Source Income or FDII calculations. |
CF- Carryforward | Attribute generated in a prior year which is available to offset current or future taxable income or tax due. |
OECD - Organisation for Economic Co-operation and Development | International organization comprised of member countries which work together to develop policy standards to promote sustainable economic growth |
QDMTT - Qualified Domestic Minimum Top-up Tax | Minimum tax included in domestic law to increase domestic tax liability to a minimum rate, as defined by Article 10 of the OECD Pillar Two Model Rules. |
IIR - Income Inclusion Rule | Rule which requires a parent entity to include a share of income from subsidiaries located in a low-tax jurisdiction when calculating a top-up tax under Pillar Two. |
UTPR - UnderTaxed Profits Rule | Acts as backstop to the IIR which collects necessary top-up tax which was not collected under an IIR. |
STTR - Subject to Tax Rule | Model treaty provision to be included in double tax treaties which allows a source State to recapture taxing rights on certain intragroup payments. |