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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.
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 ...
1 lis 2022 · A CFC’s QBAI is its average quarterly tax basis in depreciable tangible property used in a trade or business (tracked using the alternative depreciation system method) for the production of tested income (see Sec. 951A(d)).
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).
23 lip 2020 · The GILTI high-tax exclusion in section 951A permits U.S. shareholders of CFCs to elect to exclude certain high-taxed income from gross tested income. The final regulations provide guidance on which types of high-taxed income are eligible for the high-tax exclusion.
1 sty 2019 · Under the TCJA, Sec. 951A is effective for tax years of foreign corporations beginning after Dec. 31, 2017, and for tax years of U.S. shareholders with or within which those tax years of the foreign corporations end.
Except as provided in subparagraph (B), any global intangible low-taxed income included in gross income under subsection (a) shall be treated in the same manner as an amount included under section 951(a)(1)(A) for purposes of applying sections 168(h)(2)(B), 535(b)(10), 851(b), 904(h)(1), 959, 961, 962, 993(a)(1)(E), 996(f)(1), 1248(b)(1), 1248 ...
