Regulations: GILTI and subpart F high-tax exception (text of final and proposed regulations)

Regulations: GILTI and subpart F high-tax exception

The U.S. Treasury Department and IRS this afternoon released for publication in the Federal Register final regulations (T.D. 9902) and a notice of proposed rulemaking (REG-127732-19) concerning the “global intangible low-taxed income” (GILTI) and subpart F income provisions regarding the treatment of income that is subject to a high rate of foreign tax.

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These regulations are related to changes made by the 2017 tax law (Pub. L. No. 115-97)—the law that is often referred to as the “Tax Cuts and Jobs Act” (TCJA).

  • Read the final regulations [PDF 434 KB] (30 pages as published in the Federal Register) that provides guidance under sections 951A and 954 regarding the income subject to a high rate of foreign tax.
  • Read the proposed regulations [PDF 418 KB] (26 pages as published in the Federal Register) that provides guidance under section 954(b)(4) regarding income subject to a high rate of foreign tax

The purpose of this report is to provide text of the final and proposed regulations. Analysis of these regulations will be provided in a future KPMG report.

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