Proposed Regulations Related to Previously Taxed Income (PTI) Are Expected This Year

Marjorie Rollinson, IRS Associate Chief Counsel International, has indicated that issuing new proposed PTI regulations is a priority for the IRS this year. The new PTI regulations would address issues related to the global intangible low-taxed income (GILTI) and deemed repatriation provisions of the Tax Cuts and Jobs Act, specifically, how to allocate deductions against tested income for CFCs and how to treat GILTI inclusions in excess of E&P.

Read More: Proposed U.S. Regs on Previously Taxed Income Coming This Year

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