Tuesday, June 18, 2019

Washington - IRS and Treasury issue guidance related to global intangible low-taxed income (GILTI)

The Treasury Department and the Internal Revenue Service issued final and proposed regulations today concerning global intangible low-taxed income under section 951A, the foreign tax credit, the treatment of domestic partnerships for purposes of determining the subpart F income of a partner, and the treatment of income of a controlled foreign corporation subject to a high rate of foreign tax under section 951A.

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