Foreign Reporting—IRS Issues Final Regulations on GILTI and Subpart F Income:

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Foreign Reporting—IRS Issues Final Regulations on GILTI and Subpart F Income:

Posted by Kim Chen on August 31st, 2019

The IRS has released final regulations on determining the amount of Global Intangible Low-taxed Income (GILTI) included in the gross income of certain U.S. shareholders of foreign corporations, including U.S. shareholders that are members of a consolidated group. The final regulations also address the determination of a U.S. shareholder’s pro rata share of a controlled foreign corporation’s subpart F income, as well as certain requirements for reporting inclusions of subpart F income and GILTI. In addition, the IRS has provided final regulations on certain foreign tax credit provisions applicable to persons that directly or indirectly own stock in foreign corporations. The final regulations, which retain the basic approach and structure of regulations proposed by the IRS in September 2018, generally apply to tax years of foreign corporations beginning after 12/31/17 and to tax years of U.S. shareholders in which or with which such tax years of foreign corporations end. TD 9866.