IR-2020-165, July 20, 2020

WASHINGTON — The Department of the Treasury and the Internal Revenue Service today issued a final regulation (PDF) addressing the treatment of income earned by certain foreign corporations that is subject to a high rate of foreign tax.

The final regulations allow taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their Global Intangible Low Taxed Income (GILTI) computation on an elective basis.

Treasury and the IRS today also issued a proposed regulation (PDF) regarding the high-tax exception with the GILTI high-tax exclusion. Treasury and the IRS welcome public comments.

Updates on the TCJA can be found on the Tax Reform page of

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