On 13 September 2018, the U.S. IRS issued the proposed Guidance Related to Section 951A (Global Intangible Low-Taxed Income), which has been submitted to the Federal Register for publication. --- WASHINGTON — The Internal Revenue Service issued proposed regulations today concerning global intangible low-taxed income under section 951A and related sections of the Internal Revenue Code. The Tax Cuts and Jobs Act (TCJA), passed in December 2017, made major changes to the tax law, including adding new rules requiring the inclusion of global intangible low-taxed income generated by controlled foreign corporations (CFCs). Under the TCJA, a U.S. person that owns...