KPMG report: Regulations under sections 245A, 951A, 954 (GILTI); treatment of dividends from foreign corporations
KPMG report: Regulations under sections 245A, 951A, 954
Final regulations under sections 245A and 954(c)(6) and proposed regulations under sections 245A and 951A were published in the Federal Register on August 27, 2020.
The final regulations finalize proposed regulations (2019) under sections 245A and 954(c)(6), and also withdraw temporary regulations that accompanied and served as the text of the 2019 proposed regulations.
Read a September 2020 report [PDF 439 KB] prepared by KPMG LLP that provides a description of the key provisions of the 2020 final and proposed regulations and includes key insights and observations.
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.