Baker McKenzie's North America Tax Practice Group has prepared a Tax News and Developments Client Alert on the recently proposed regulations under Section 951A that were released on September 13, 2018. The proposed regulations provide guidance with regard to various mechanical and computational aspects of the GILTI regime, along with rules for reporting requirements. The proposed regulations do not contain any rules on the foreign tax credit, (including rules on expense allocation to the section 904(d)(1)(A) GILTI basket) as it relates to GILTI. Our Client Alert provides an in-depth analysis on how the proposed regulations will impact taxpayers.
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