The IRS proposed new rules under the global intangible low-taxed income (GILTI) provision (Sec. 951A) added by P.L. 115-97, the law known as the Tax Cuts and Jobs Act (REG-104390-18). Sec. 951A requires U.S. shareholders of controlled foreign corporations (CFCs) to include in their gross income their GILTI income for that tax year (the inclusion …
Continue reading IRS issues proposed regs. for GILTI inclusions










