A notice from the U.S. IRS has been published announcing that a public hearing will be held on 13 February 2019 on the proposed regulations (REG–104390–18) on Guidance Related to Section 951A (Global Intangible Low-Taxed Income). The proposed regulations provide for the implementation of section 951A of the Internal Revenue Code, which includes new rules requiring the inclusion of global intangible low-taxed income (GILTI) generated by controlled foreign corporations (CFCs). These new rules …