American Expat Financial News: Partial' GILTI tax victory seen in latest Treasury regs
The U.S. Treasury Department on Monday issued what it said was a "final regulation" addressing how income earned by foreign corporations that has already been subject to a high rate of foreign tax may declared, in order to "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".
At the same time it and the IRS issued what was described as a proposed regulation "regarding the high-tax exception with the GILTI high-tax exclusion", and invited the public and other stakeholders to comment on it....
On a personal note, I would like to thank Helen for the WONDERFUL job she is doing and has done in the service of expats! Truly hard labor of love! She deserves our admiration and support!