New Domestic Partnership Rules Under the Final GILTI Regulations
The Tax Cuts and Jobs Act of 2017 enacted Section 951A of the Internal Revenue Code in order to prevent base erosion which requires a U.S. shareholder of any Controlled Foreign Corporation to include in gross income the Shareholder’s global intangible low-taxed income (GILTI). On June 21, the IRS and the Treasury Department published final regulations for the GILTI ru [...]