Treasury, IRS Issue Final and Proposed Regulations on Income Subject to a High Rate of Foreign Tax

July 21, 2020

The Department of the Treasury and IRS recently issued a final regulation addressing the treatment of income earned by certain foreign corporations that is subject to a high rate of foreign tax.

The final regulations allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their Global Intangible Low Taxed Income (GILTI) computation on an elective basis.

The Treasury and IRS also issued a proposed regulation regarding the high-tax exception with the GILTI high-tax exclusion. They welcome public comments on the proposed regulation.

For more information, visit the IRS’ Tax Reform page.