WebAug 5, 2024 · Conformity to subpart F high-tax exception: A separate set of proposed regulations attempts to conform the rules implementing the subpart F high-tax exception … WebThe most significant departures are that an election to apply the GILTI high-tax exception may be made annually instead of once every five years, and that the calculation is made with respect to each “tested unit” (as defined below) of a controlled foreign corporation (CFC), rather than on a qualified business unit (QBU)-by-QBU basis.
Inside Deloitte GILTI high-tax exclusion: Impact on …
WebApr 13, 2024 · If a taxpayer’s GILTI inclusion has an effective tax rate of at least 18.9 percent (90 percent of the current U.S. corporate rate of 21 percent), calculated based on U.S. tax … WebJul 29, 2024 · The high-tax exception in Reg. §1.951A-2 (c) (7) allows a taxpayer to elect to exclude from tested income, under Sec. 954 (b) (4), a so-called tentative gross tested income item if that income was subject to an effective rate of foreign tax that is greater than 90% of the Sec. 11 rate (i.e. 18.9% = 21% * 90%). [4] shannon morrison apha
Final regulations clarify potential benefits of the GILTI high-tax ...
WebAug 5, 2024 · Procedure for making the election: The controlling domestic shareholder of a CFC or CFC group may claim the high-tax exclusion on an annual basis by filing an election statement and, if needed, providing notice to all other persons known by the controlling shareholder to be domestic shareholders. WebEffective Foreign Tax Rate. “Consistent with section 954 (b) (4), the 2024 proposed regulations apply the GILTI high-tax exclusion by comparing the effective foreign tax rate with 90 percent of the rate that would apply if the income were subject to the maximum rate of tax specified in section 11 (currently 18.9 percent, based on a maximum ... WebMar 16, 2024 · If you're a US shareholder of a controlled corporation (CFC), meaning you own more than 50% of the total value or combined voting power of a company based outside of the US, you should be aware of Global Intangible Low Taxed Income (GILTI). polyzincliothyronine