United States Issues Final GILTI Regulations


By Global Tax Weekly

The US Treasury Department and the Internal Revenue Service (IRS) have issued final regulations concerning the global intangible low-taxed income (GILTI) regime under Section 951A, as well as final and proposed regulations concerning foreign tax credits, domestic partnerships, subpart F income, and the treatment of certain controlled foreign corporation (CFC) income.

According to the IRS, the final GILTI regulations provide guidance to determine the amount of global intangible low-taxed income included in the gross income of certain US shareholders of foreign corporations, including US shareholders who are members of a consolidated group.

The final GILTI regulations retain, with certain modifications, the anti-abuse provisions that were included in the proposed regulations and revise the domestic partnership provisions to adopt an aggregate approach for purposes of determining the amount of global intangible low-taxed income included in the gross income of a partnership’s partners under Section 951A with respect to CFCs owned by the partnership.

The final regulations also provide guidance relating to the determination of a US shareholder’s pro rata share of a CFC’s subpart F income and global intangible low-taxed income included in the United States shareholder’s gross income, as well as certain reporting requirements relating to inclusions of subpart F income and global intangible low-taxed income.


For more information on this, and other topical international tax matters, please visit: https://www.cchgroup.com/roles/corporations/international-solutions/research/global-tax-weekly-a-closer-look





Leave a Reply

Your email address will not be published. Required fields are marked *

You may use these HTML tags and attributes: <a href="" title=""> <abbr title=""> <acronym title=""> <b> <blockquote cite=""> <cite> <code> <del datetime=""> <em> <i> <q cite=""> <strike> <strong>



RELATED ARTICLES AND INFORMATION

OECD Releases BEPS Action 14 Peer Reviews

On February 16, the OECD released the final batch of BEPS Action 14 peer reviews, on the efforts of 13 jurisdictions to improve how...

EU Reports On Brexit Impact

The EU has been mulling over the anticipated economic impact of the Brexit split. Releasing its Winter 2021 Economic Forecast, the EU suggested that...

India Reduces Time-Period For Investigations

The Indian Government has announced its intention to reduce the time-period during which the tax authority can probe an individual’s tax affairs. Under the...