Initial impressions about final and proposed regulations, high-tax exception under GILTI and subpart F

Initial impressions on final and proposed regulations

The U.S. Treasury Department and IRS yesterday, July 20, 2020, released for publication in the Federal Register final regulations (T.D. 9902) related to the “global intangible low-taxed income” (GILTI) high-tax exception and proposed regulations (REG-127732-19) which would establish uniformity between the historic subpart F high-tax exception in section 954(b)(4) and the final GILTI high-tax exception by providing for a single high-tax exception.

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Read a July 2020 report [PDF 258 KB] prepared by KPMG LLP that provides an initial impression and description of the key provisions of the final regulations and the proposed regulations. In a future release, KPMG will provide a more detailed analysis of these regulations, including key insights and observations. 

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