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June 25, 2019

GILTI as charged (Part 2): The Final Regs and High Tax Exception

Doug McHoney (PwC's International Tax Services Leader) interviews Elizabeth Nelson (International Tax Services Partner) and Aaron Junge (International Tax Services Director) about the final and newly proposed GILTI regulations. Elizabeth and Aaron walk through the key changes in the regulations, including, narrowing the scope of the pro rata share anti-abuse rule, the aggregate treatment of US partnerships, the broader basis step up anti-abuse rules, the reservation on basis adjustment rules for tested loss, the legal and retroactive effect of regulations, and the high tax exception.

Duration: 37:20

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Doug McHoney

International Tax Services Co-Leader, PwC US

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

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