Much has certainly been written about the recently proposed regulations on IRC §951A known more famously as the Global Intangible Low-Taxed Income (“GILTI”) regime.  What has not been widely publicized are the basis adjustment rules for consolidated groups.  This may not be the most easily understood topic but it may be one of the most important topics to groups that are active or expect to be active in the merger & acquisition arena.  The GILTI basis adjustment rules are a new area of complexity and risk.