The IRS has issued final regulations under the global intangible low-taxed income (GILTI) provisions regarding the treatment of income that’s subject to a high rate of foreign tax.

July 23, 2020

In a nutshell, the final regs allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their GILTI computation on an elective basis.

In addition, the IRS issued proposed regs that would generally conform the rules implementing the “subpart F” high-tax exception to the rules implementing the GILTI high-tax exclusion.

The final regulations go into effect on Sept. 21, 2020.

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