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.

This article discusses some of the key issues and challenges associated with these new final and proposed regulations.


The Tax Cuts and Jobs Act purportedly moved the U.S. toward a territorial system of taxation of foreign earnings by permitting certain income of a foreign corporation to be repatriated back to the U.S. without U.S. tax....

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