Proposed GILTI Regulations Released
The IRS has released proposed regulations on global intangible low-tax income (GILTI) under section 951A, a provision added by the Tax Cuts and Jobs Act. The proposed regulations set forth rules for calculating the GILTI inclusion and new reporting requirements, but do not address foreign tax credit rules, which will be addressed separately in the future. Public comments on the proposed regulations are due by 60 days after the proposed regulations are published in the federal register.
Read the proposed regulations here: REG-104390-18
Read more here: IRS issues proposed regulations on global intangible low-taxed income for U.S. shareholders