IRS Issues Final and Proposed Regulations with Respect to the GILTI and Subpart F High-Tax Exclusions
On July 20, the IRS released final regulations that allow taxpayers to elect out of the global intangible low-taxed income (GILTI) provisions if the income is subject to a rate of at least 18.9% in a foreign country. Proposed regulations were also released that generally would revise the subpart F high-tax exception to be consistent with the provisions of the GILTI high-tax exception.
Read More: Final Regulations
Read More: Proposed Regulations