US Tax Readiness: The High Tax Exception - GILTI and Subpart F
US Treasury released Final and Proposed Regulations relating to the treatment of income that is subject to a high rate of foreign tax under the GILTI and subpart F income regimes. The Final Regulations largely adopt the approach taken in the 2019 Proposed Regulations with some modifications to the methodology used to determine income attributable to a QBU (now referred to as a tested unit) and determining the CFC group. The Proposed Regulations bring the high-tax exception for subpart F income purposes in conformity with the GILTI high-tax exception so that a unified election applies.
Date: Thursday, 30 July 2020
Time: 7pm UK (2PM ET)
