Back in March, Sciarabba Walker’s international tax blog covered a new U.S. revenue stream created by the Tax Cuts and Jobs Act (TCJA) of 2017 – global intangible low-taxed income (GILTI). On June 14th, the IRS issued final regulations providing guidance “to determine the amount of GILTI included in the gross income of certain U.S. shareholders of foreign corporations, including U.S. shareholders who are members of a consolidated group.”
The final regulations also shed light on determining a “U.S. shareholder’s pro rata share of a controlled foreign corporation’s subpart F income and global intangible low-taxed income included in the U.S. shareholder’s gross income, as well as certain reporting requirements relating to inclusions of subpart F income and global intangible low-taxed income.”
We will keep you informed on this topic as it develops. If you have any questions about GILTI, please reach out to our International Tax Group.