July 29, 2020
GILTI High-Tax Exception Final Regulations
While the final regulations maintain the basic framework of the proposed high-tax exclusion, there are some significant changes. In this blog post, GILTI High-Tax Exception Final Regulations, This article examines these changes, which include the determination of the foreign effective rate of tax on a newly defined tested unit, rather than QBU-by-QBU, basis; the ability to elect the high-tax exclusion retroactively to the 2018 taxable year; and the ability to make the election on a yearly basis. This article will also help you assess the impact of the final regulations on your company’s overall international tax profile.