Executive summaryOn 21 August 2020, the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) released taxpayer-favorable proposed regulations under Internal Revenue Code1 Sections 245A and 951A (REG-124737-19) to coordinate two independent sets of anti-abuse rules that apply to extraordinary dispositions and disqualified transfers (together, EDs). Both rules apply to certain transactions of a controlled foreign corporation (CFC) occurring during the so-called global intangible low-taxed income (GILTI) gap period. Absent the proposed regulations, gain recognized in an ED effectively could be taxed twice:Once, in the form of a taxable dividend distributed by a CFC (because the dividend is deemed...