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14 cze 2019 · IR-2019-114, June 14, 2019 — The Treasury Department and the Internal Revenue Service issued final and proposed regulations today concerning global intangible low-taxed income under section 951A, the foreign tax credit, the treatment of domestic partnerships for purposes of determining the subpart F income of a partner, and the treatment of ...
On September 13, 2018, Treasury released GILTI proposed regulations (the “2018 proposed regulations”), which provided guidance on both the shareholder-level computations and the CFC-level computations required for determining a U.S. Shareholder’s GILTI inclusion.
Section 951 (a) (1) requires a United States shareholder (hereafter “US shareholder”) of a controlled foreign corporation (CFC) to include certain amounts in gross income on a current basis, thus preventing deferral of US tax on that income.
IRC 951A applies to taxable years of foreign corporations beginning after December 31, 2017, and to taxable years of U.S. shareholders in which or with which such taxable years of foreign corporations’ end.
10 paź 2018 · Section 951A (a) provides that a U.S. shareholder of any CFC for a taxable year must include in gross income its GILTI for that year. A GILTI inclusion is treated in a manner similar to a section 951 (a) (1) (A) inclusion of a CFC's subpart F income for many purposes of the Code. See section 951A (f) (1).
10 gru 2018 · The IRS released guidance on the determination of the foreign tax credit. Learn about the changes to Section 904, Section 960, Section 954 and Section 78.
Treasury and the IRS on June 14, 2019 released 318-page final regulations (the Final Regulations) and 74-page proposed regulations (the Proposed Regulations) under Section 951A as enacted by the 2017 tax reform legislation (the Act) and provisions related to implementing Section 951A.
