This column is reprinted with the publisher’s, Wolters Kluwer, permission from Global Tax Weekly, and originally appeared on page 26, April 5th edition.

We are several months into the new tax regime, and we in the tax community are still wrapping our heads around the complex and far-reaching new provisions. The Republicans' goal of a simplified, territorial system was clearly lost on the drafters, as we now live under an even more complicated set of rules that may be more akin to a pure worldwide tax system, largely thanks to one provision: Global Intangible Low-Taxed Income, or GILTI.