The IRS recently released proposed regulations that provide Treasury guidance with regards to Global Intangible Low Taxed Income ("GILTI").  For U.S. companies with foreign operations, it is vital that a valuation of the company includes a liability associated with a GILTI tax where appropriate.  As the GILTI tax treats certain non-U.S. income as taxable income in the U.S., not capturing the GITLI tax liability would result in an overvaluation of the company given the GILTI tax increases the overall effective tax rate of the company.