Final and new proposed GILTI regs and temporary DRD regs released

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June 2019


Today, Treasury released final regulations (318 pages) under Section 951A. Treasury also released proposed regulations (74 pages), regarding the treatment of domestic partnerships for purposes of determining amounts included in the gross income of their partners with respect to foreign corporations. In addition to the proposed and final GILTI regulations, Treasury released temporary regulations (105 pages) under Section 245A which limits the dividends received deduction available for certain dividends received from current or former CFCs.

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Kelley McLaughlin

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