PE sponsors and investors have been grappling with the ramifications of the final Global Intangible Low Tax Income (GILTI) Treasury Regulations that recently became effective (Final Regulations). GILTI generally provides relief for certain U.S. investors in a PE fund structured as a domestic partnership that owns foreign portfolio company investments. Although the Final Regulations have generally become more taxpayer-friendly in the treatment of domestic partnerships, PE funds should be aware of certain limitations of these new rules – especially in the context of tiered partnerships. In a guest article, Gibson, Dunn & Crutcher partner Edward S. Wei provides a selected overview of the Final Regulations, with examples of the tax ramifications of certain structural approaches under the Final Regulations compared to the previous iteration of the GILTI rules. See “How the Tax Cuts and Jobs Act Will Affect Private Fund Managers and Investors” (Feb. 22, 2018); and “New Tax Law Carries Implications for Private Funds” (Feb. 1, 2018).