The technical corrections broaden the scope of permissible disallowances under the cost recovery requirement. More foreign tax credit guidance, however, is anticipated. The technical corrections to the global intangible low-taxed income (GILTI) high-tax exclusion limit the foreign taxes taken into account for purposes of determining the effective rate of foreign tax on a tested income item. Taxpayers planning to make the GILTI high-tax exclusion election may be required to recognize more tested income than they anticipated.Executive summaryOn 27 July 2022, the United States (US) Treasury Department published technical corrections (87 FR 45018, the Technical Corrections) to controversial final regulations (T.D....