Treasury, IRS issue final and proposed regulations on income subject to a high rate of foreign tax
An official website of the United States Government
IR-2020-165, July 20, 2020
WASHINGTON — The Department of the Treasury and the Internal Revenue Service today issued a final regulation (PDF) addressing the treatment of income earned by certain foreign corporations that is subject to a high rate of foreign tax.
The final regulations allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their Global Intangible Low Taxed Income (GILTI) computation on an elective basis.
Treasury and the IRS today also issued a proposed regulation (PDF) regarding the high-tax exception with the GILTI high-tax exclusion. Treasury and the IRS welcome public comments.
Updates on the TCJA can be found on the Tax Reform page of IRS.gov.
An official website of the United States Government
IR-2020-165, July 20, 2020
WASHINGTON — The Department of the Treasury and the Internal Revenue Service today issued a final regulation (PDF) addressing the treatment of income earned by certain foreign corporations that is subject to a high rate of foreign tax.
The final regulations allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their Global Intangible Low Taxed Income (GILTI) computation on an elective basis.
Treasury and the IRS today also issued a proposed regulation (PDF) regarding the high-tax exception with the GILTI high-tax exclusion. Treasury and the IRS welcome public comments.
Updates on the TCJA can be found on the Tax Reform page of IRS.gov.
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