Treasury Says Final GILTI High-Tax Exception Is Retroactive

Law360 (July 20, 2020, 4:59 PM EDT) -- The U.S. Treasury Department finalized Monday a partial tax exemption for companies that have already paid high foreign taxes on global income, and will allow businesses to apply the exemption retroactively to the end of 2017.

The U.S. Treasury Department finalized rules Monday that will allow companies to choose to apply the global intangible low-taxed income high-tax exclusion to taxable years back to Dec. 31, 2017. (AP) Under the exemption, the 10.5% tax on global intangible low-taxed income, part of the 2017 Tax Cuts and Jobs Act, won't apply to foreign income that has already been taxed by other jurisdictions at...

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