Press Room

7 Aug 2020

IRS issues guidance on GILTI high-tax exclusion


The Treasury and IRS have issued final regulations (T.D. 9902) allowing taxpayers to exclude certain high-taxed income of a controlled foreign corporation (CFC) from their global intangible low-taxed income (GILTI) computation on an elective basis. Proposed regulations (REG-127732-19) were also released, which conform the provisions addressing high-taxed subpart F income to the final rules implementing the GILTI high-tax exclusion. The final regulations give taxpayers the ability to retroactively apply the GILTI high-tax exclusion on an amended return and claim refunds for overpayments of tax in prior years.

Detailed commentary from Andersen US on the final and proposed regulations can be found at the following link.


Julian Nelberg

Julian is Head of the Private Client group at Andersen Tax in the United Kingdom. His clients include international high net worth individuals, senior executives, trusts and companies.

Email: Julian Nelberg