EYUS Treasury and the IRS propose complex, taxpayer-favorable regulations to reduce possibility of double taxation caused by anti-abuse rules on GILTI gap period
|Tax Alerts, National/Federal Taxation, L ...|United States
Executive summary
On 21 August 2020, the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) released taxpayer-favorable proposed regulations under Internal Revenue Code1 Sections 245A and 951A (REG-124737-19) to coordinate two independent sets of anti-abuse rules that apply to extraordinary dispositions and disqualified transfers (together, EDs). Both…
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