Comments on the proposed GILTI regulations recommended that a high-tax exception similar to the one under Subpart F should be provided for GILTI. The U.S. Department of the Treasury and the IRS agreed and added the GILTI high-tax exclusion (HTE) when the final GILTI regulations were released in July 2020. Portions of the regulations, including the GILTI HTE, were made retroactive to the 2018 tax year, the first year GILTI was applicable. Following are five things taxpayers should understand about making the GILTI HTE.
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