On July 23, 2020, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations addressing the global intangible low-taxed income (GILTI) high-tax exclusion (85 FR 44620) (the “Final...more
8/10/2020
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U.S. Treasury
Following the 2017 Tax Act, a domestic corporate purchaser of stock in a controlled foreign corporation (CFC) generally will desire to make a section 338(g) election. A section 338(g) election provides a stepped-up basis in...more
The 2017 tax act added two new separate foreign tax credit limitation categories, or baskets. Under current law, there are now baskets for income attributable to a foreign branch (the foreign branch basket) and for amounts...more