IRS issues final GILTI regulations: What’s next?

IRS issues final GILTI

On June 21, 2019, the Treasury Department and Internal Revenue Service released final regulations on Global Intangible Low-Taxed Income (GILTI) provisions of the 2017 tax law. What has changed? What remains the same?  What impact will this have on your future tax planning (and prior transactions)?  Please join our panel of specialists, who will discuss: 

  • The final Section 951A regulations, including rules associated with controlled foreign corporation (CFC) inclusion year, excess qualified business asset investment (QBAI), computation of tested income and losses, and determination of QBAI.
  • Insights on the expanded elective GILTI high tax exclusion that applies to certain high-taxed income, including making the election, calculation of high taxed income, and impact on attributes.
  • Certain Foreign Tax Credit Regulations that were finalized as part of the same package and may impact your prior year treatment of certain transactions.

Learning Objectives

At the conclusion of the webcast, participants should be able to:

  • Describe the final Section 951A regulations, including rules associated with controlled foreign corporation (CFC) inclusion year, excess qualified business asset investment (QBAI), computation of tested income and losses, and determination of QBAI.
  • Define the expanded elective GILTI high tax exclusion that applies to certain high-taxed income, including making the election and impact on attributes.
  • Calculate the high taxed income 
  • Appraise certain Foreign Tax Credit Regulations that were finalized as part of the regulation package and may impact on prior year treatment of certain transactions.

Register Now for this FREE On Demand webinar

Brought to you by Deloitte. Duration: 58 minutes