If nothing else, the two particular rules that I’ve been writing about so far are cleverly named – BEAT (for “base anti-erosion tax”) and GILTI (for “global intangible low-taxed income”). Less so for the third that I’ll get to later this month, FDII (for “foreign-derived intangible income”).
Tax article writers have already been having much fun in their titles with both names. E.g., “Get With the BEAT,” “More GILTI Than You Thought,” and “Guilty as Charged.”
By contrast, my current article title is “Does the United States Now Have a ‘Territorial’ Tax System?” I answer this question “NO” by the top of page 2, and then get on with the rest of it.
But I couldn’t help thinking of how GILTI might be renamed, without any loss of acroynmic punch. Suppose it were called “Foreign Intangible Low-taxed or Tax Haven Income.” This would support using the acronym FILTHI.