IRS Issues Final Regs for GILTI and Proposed Regs for the Subpart F Income High Tax Exception

On July 20, 2020, final regulations (Final Regulations) were released by the United States (U.S.) Department of Treasury (Treasury) related to the global intangible low-taxed income (GILTI) inclusion under Section 951A (Treasury Decision 9902), which was originally enacted under Tax Cuts and Jobs Act, Public Law 115-97 on Dec. 22, 2017, alongside new proposed regulations under Section 954(b)(4) (Proposed Regulations) related to high-tax subpart F income.