The IRS has issued final regs under the global intangible low-taxed income (GILTI) and subpart F income provisions of the Code regarding the treatment of income that is subject to a high rate of foreign tax.
Checkpoint will provide additional information about the regs in a future Federal Tax Update.
To continue your research on global intangible low-taxed income under Code Sec. 951A, see FTC 2d/FIN ¶O-2790 et seq.; United States Tax Reporter ¶951A4.
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