INT 18-03: Additional Elements Under the Tax Cuts and Jobs Act

INT 18-03: Additional Elements Under the Tax Cuts and Jobs Act provides additional guidance related to the federal Tax Cuts and Jobs Act in relation to the following three items:

  • Repatriation Transition Tax (RTT)
  • Alternative Minimum Tax (AMT) Credit
  • Global Intangible Low-Taxed Income (GILTI)

This interpretation provides limited-time guidance for these items with subsequent revisions around GILTI expected to be incorporated into SSAP No. 101 – Income Taxes once the FASB formally addresses GILTI for U.S. GAAP purposes (RTT and AMT Credit are limited-time issues not expected to be included in revisions to SSAP No. 101).

Also of interest, the latest revision of this guidance states that any “accounting change required by INT 18-03 shall, if not otherwise covered by INT 18-01, be recognized as a change in accounting estimate, pursuant to SSAP No. 3 – Accounting Changes and Corrections of Errors.” As a reminder, INT 18-01 provides a limited-time, limited-scope exception to SSAP No. 3 – Accounting Changes and Corrections of Errors to eliminate the requirement for recognition of changes in reasonable estimates from the Tax Cuts and Jobs Act as Type I subsequent events after the issuance of the statutory financial statements.

The interpretation can be found here. The AP&P exposure related to this can be found here. INT 18-01 can be found here.