The U.S. Senate Committee on Finance has issued a release on the introduction of a draft bill by Senator Ron Wyden (D-OR) and Senator Sherrod Brown (D-OH) to limit the GILTI high-tax exclusion. As provided in the bill, it would amend the Internal Revenue Code of 1986 to clarify that high-taxed amounts are excluded from tested income for purposes of determining global intangible low-taxed income (GILTI) only if such amounts would be foreign base company income or insurance income.
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