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U.S. IRS and Treasury Issue Correction to Proposed Rulemaking on Hybrid Arrangements and GILTI

12 August 2020

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Approved Changes

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United States

The U.S. IRS and Treasury have issued corrections to proposed rulemaking (guidance) involving hybrid arrangements and the allocation of deductions attributable to certain disqualified payments under Section 951A (Global Intangible Low-Taxed Income). --- SUMMARY: This document contains a correction to a notice of proposed rulemaking that was published in the Federal Register on April 8, 2020. The proposed regulations that adjust hybrid deduction accounts to take into account earnings and profits of a controlled foreign corporation that are included in income by a United States shareholder. DATES: This correction is effective on August 11, 2020 and is applicable beginning April...