Treasury Crafts GILTI Exception For High-Taxed Global Income

Law360 (June 14, 2019, 5:30 PM EDT) -- The U.S. Department of the Treasury released proposed regulations on Friday that would expand an exception to the federal tax overhaul's global minimum tax, applying to global income that has already been taxed by foreign jurisdictions.

A proposal by the U.S. Department of the Treasury would allow companies an exemption to the tax on global intangible low-taxed income if they have paid foreign taxes at 90% of the U.S. rate. (AP) The proposed regulations would allow U.S. companies to elect an exemption to the Tax Cuts and Jobs Act's global intangible low-taxed income if they've already paid foreign taxes equal to...

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