Treasury and IRS Allow Domestic Partnerships and S Corporations to Apply Certain Proposed GILTI Regulations to Taxable Years Ending Before June 22, 2019

The Department of the Treasury (Treasury) and the IRS recently released Notice 2019-46.  The notice allows a domestic partnership or S corporation to apply Prop. Treas. Reg. § 1.951A-5 to taxable years ending before June 22, 2019, so long as the domestic partnership or S corporation meets the notification and reporting requirements described in the notice.  Prop. Treas. Reg. § 1.951A-5 addresses the treatment of global intangible low-taxed income (GILTI) inclusion amounts and adjustments to earnings and profits to account for tested losses.

Read More:  Notice 2019-46

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