Eversheds Sutherland Tax Reform Law Blog
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OIRA Completes Review of Final Regulations on the GILTI High-Tax Exclusion

On July 7, the Office of Information and Regulatory Affairs (OIRA) completed its review of final regulations under section 951A relating to the proposed high-tax exclusion for global intangible low-taxed income (GILTI) and its review of proposed regulations under section 954(b)(4) relating to high-tax subpart F income. Among other provisions, the proposed version of the regulations had...