they’ll just add this income to all the other income they’re paying taxes on, and then calculate income tax on GILTI just like it’s Subpart F income.
On September 13, the IRS and Treasury released proposed regulations under the global intangible low-taxed income (GILTI) provisions added by the Tax Cuts and Jobs Act of 2017 (TCJA). The GILTI regime is intended to ensure U.S. taxpayers pay at least some U.S. tax on low-taxed or unta...
“subpart F income” inclusions, which now also apply for GILTI purposes. Notably, the Proposed Regulations do not provide guidance on the deduction used to reduce the effective tax rate on GILTI to 10.5 percent (through 2025) or 13.125 percent (after 2025) or foreign tax credits ...
in light of the December 2019 proposed regulations relating to foreign tax credits (2019 Proposed FTC Regulations), the final regulations make changes to how certain expenses are apportioned. The preamble to the final regulations states that Treasury and the IRS will consider...
Are you owed a tax refund? The importance of modeling the GILTI High Tax Exclusion On July 20, 2020, the U.S. Department of the Treasury and the Internal Revenue Service issued the final regulations regarding the election to exclude high-tax Global Intangible Low-Taxed Income (GILTI) from a...
The IRS proposed regulations state that an individual making the Section 962 election is subject to the 21% corporate tax rate and can get the special 50% deduction for GILTI income, which lowers its tax on GILTI to 10.5%. The IRS has not yet specifically confirmed that an individual can ...