3. The TCJA brought to the fore several new International tax concepts:

New Code Sec. 951A Subpart F inclusion for the global intangible low-taxed income (or GILTI) of a controlled foreign corporation.

New Code Sec. 250 deduction based on a domestic corporations Subpart F inclusion for GILTI as well as any foreign-derived intangible income (or FDII) that a domestic corporation derives directly from export sales.

New Code Sec. 59A tax on base erosion payments that certain large domestic corporations make to a related foreign person. This so-called base erosion and anti-abuse tax (or BEAT) is paid in addition to the regular corporate income tax.

(a) How do these NEW code sections create a carrot and stick which encourages U.S. companies to:

1. hold their high-value intangible property in the United States rather than offshore and,

2. prevent US base stripping

(b) Briefly explain the difference between GILTI and FDII