On 14 June 2019, the U.S. IRS announced the issuance of the following final and proposed regulations, which are scheduled to be published in the Federal Register on 21 June 2019:

• Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits
• Guidance under Section 958 (Rules for Determining Stock Ownership) and Section 951A (Global I…