Eversheds Sutherland Tax Reform Law Blog
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IRS Issues Final and Proposed Regulations with Respect to the GILTI and Subpart F High-Tax Exclusions

On July 20, the IRS released final regulations that allow taxpayers to elect out of the global intangible low-taxed income (GILTI) provisions if the income is subject to a rate of at least 18.9% in a foreign country. Proposed regulations were also released that generally would revise the subpart F high-tax exception to be consistent with the provisions of the GILTI high-tax exception....