U.S. Chamber Seeks Changes to Subpart F High-Tax Exception Regs

U.S. Chamber Seeks Changes to Subpart F High-Tax Exception Regs

U.S. Chamber of Commerce

The U.S. Chamber of Commerce has commented on proposed regulations (REG-127732-19) under the subpart F income and global intangible low-taxed income provisions, suggesting changes regarding several issues including that the GILTI and subpart F income high-tax exclusions should not be combined into a single election and that the definition of a controlled foreign corporation group be refined.

The U.S. Chamber of Commerce has commented on proposed regulations (REG-127732-19) under the subpart F income and global intangible low-taxed income provisions, suggesting changes regarding several issues including that the GILTI and subpart F income high-tax exclusions should not be combined into a single election and that the definition of a controlled foreign corporation group be refined.

The U.S. Chamber of Commerce has commented on proposed regulations (<a href="/lr/resolve//2cr1g">REG-127732-19</a>) under the subpart F income and global intangible low-taxed income provisions, suggesting changes regarding several issues including that the GILTI and subpart F income high-tax exclusions should not be combined into a single election and that the definition of a controlled foreign corporation group be refined.