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IRS Issues Proposed Regs for GILTI Inclusions

The IRS proposed new rules under the global intangible low-taxed income (GILTI) provision (Sec. 951A) added by the Tax Cuts and Jobs Act. Sec. 951A requires U.S. shareholders of controlled foreign corporations (CFCs) to include in their gross income their GILTI income for that tax year (the inclusion amount). The new provision applies to tax years of foreign corporations beginning after Dec. 31, 2017, and t ...

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