On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19) that will provide significant ...
Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax ...