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IRS releases final GILTI regulations

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Tax Hot Topics newsletter The IRS released final (T.D. 9866) and proposed (REG-101828-19) regulations on June 14 addressing a variety of topics including global intangible low-taxed income (GILTI), foreign tax credits, the treatment of domestic partnerships for purposes of determining Subpart F income of a partner, and a so-called “GILTI high-tax exclusion.” The final regulations afford much needed certainty to taxpayers, but were largely upstaged by the proposed GILTI high-tax exclusion that could redefine the GILTI paradigm.

For more details, see our Tax Flash.

Contacts:
David Sites
Partner
Washington National Tax Office 
T +1 202 861 4104

David Zaiken
Managing Director
Washington National Tax Office 
T +1 202 521 1543

Cory Perry
Senior Manager
Washington National Tax Office 
T +1 202 521 1509

Mike Del Medico
Manager
Washington National Tax Office 
T +1 202 521 1522

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