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U.S. IRS and Treasury Issue Corrections to Regulations on Income Subject to a High Rate of Foreign Tax for GILTI

|Approved Changes|United States
United States

The U.S. IRS and Treasury have issued a correction and correcting amendment to the final regulations (TD 9902) under the global intangible low-taxed income and subpart F income provisions of the Internal Revenue Code regarding the treatment of income that is subject to a high rate of foreign tax. The correction and correcting amendment were both published in the Federal Registration on 11 December 2020 and are generally effective on that date.

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