U.S. IRS and Treasury Issues Final and Proposed Regulation on GILTI

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OECD Inclusive Framework Reaches Consensus on Pillar Two “Side by Side” Package

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…