United States (US) final regulations (TD 9902) and proposed regulations (REG-127732-19) released 20 July 2020, address the application of the high-tax exclusions from global intangible low-taxed income (GILTI) under Internal Revenue Code Section 951A(c)(2)(A)(i)(II) (the GILTI high-tax exclusion) and from subpart F income under Section 954(b)(4) (the proposed subpart F high-tax exception), respectively.The elective GILTI high-tax exclusion allows taxpayers to exclude from their GILTI inclusion items of a controlled foreign corporation’s (CFC) gross tested income subject to a high effective rate of foreign tax. The final regulations adopt the threshold rate of foreign tax of 18.9% (i.e., 90% of the highest domestic corporate tax...