High-Taxed Global Income Exclusion May Be Too Narrow

By Robert Kiggins (July 10, 2019, 3:28 PM EDT) -- On June 14, 2019, the IRS and the U.S. Department of the Treasury published final regulations[1] providing guidance to help taxpayers and their advisers determine the amount of global intangible low-taxed income, or GILTI, to be included in the gross income of affected United States shareholders of foreign corporations. In addition, on the same day these agencies published a notice[2] of proposed rulemaking regarding proposed regulations for the GILTI treatment of gross income subject to a high rate of foreign tax.

Background

Subpart F of the U.S. Internal Revenue Code has been around for many years and is designed so that...

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