EYUS: "Tested unit" standard in final GILTI regulations limits aggregating items of income, while proposed regulations would adopt the same standard for subpart F income high-tax exception
|Tax Alerts, Information Reporting, Legis ...|United States
Final regulations under Internal Revenue Code1 Section 951A (TD 9902), which were published in the Federal Register on 23 July 2020, implement an elective exclusion for high-tax global intangible low-taxed income (GILTI). Proposed regulations under Section 954 (REG-127732-19), which were published simultaneously with the final regulations, propose changes to the existing subpart F income high-tax …
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