Monday, July 20, 2020

IR-2020-165: Treasury, IRS issue final and proposed regulations on income subject to a high rate of foreign tax

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IRS Newswire July 20, 2020

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Issue Number:    IR-2020-165

Inside This Issue


Treasury, IRS issue final and proposed regulations on income subject to a high rate of foreign tax

WASHINGTON — The Department of the Treasury and the Internal Revenue Service today 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. 

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

Updates on the TCJA can be found on the Tax Reform page of IRS.gov.

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