EYUS: Notice 2020-69 provides rules on entity treatment election for certain S corporations for purposes of GILTI in AAA inclusions
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Executive summary
In Notice 2020-69 (the Notice), the United States (US) Treasury announced its intent to issue regulations addressing the application of subpart F and the global intangible low-tax income (GILTI) regime to certain S corporations with accumulated earnings and profits (AE&P) as of 1 September 2020. The Notice permits electing S corporations to apply its provis…
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