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Final GILTI Regulations to be Released Soon

21 May 2019

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Proposed Changes

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United States

Final regs on the global intangible low-taxed income provision are nearing completion, having been received for review by the Office of Information and Regulatory Affairs. The final regulations were received on 16 May according to OIRA's website. The rules are not deemed to be economically significant. Proposed rules on GILTI were released in September. The rules were largely mechanical, but practitioners are hoping for changes to several more controversial provisions especially some of the anti-abuse provisions of the proposed regulations.