July 21, 2022

We have written about GILTI before – https://htj.tax/?s=gilti The IRS published final regulations (T.D. 9902) on July 23, 2020, to address the application of the high-tax exclusion from global intangible low-taxed income (GILTI) under Sec. 951A(c)(2)(A)(i)(III). Sec. 951A, which contains the GILTI rules, was added to the Internal Revenue Code by the law known as the […]