New Unified High-Tax Election Brings Planning Challenges

By Lucas Giardelli, Michael Lebovitz and Amit Neuman (August 20, 2020, 6:33 PM EDT) -- On July 20, the U.S. Department of the Treasury issued final regulations allowing a high-tax election for global intangible low-taxed income, or GILTI, purposes and proposed a further set of regulations that would unify that election and the Internal Revenue Code Subpart F high-tax election....

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