McDermott, Will & Emery LLP recently issued the following announcement.
The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact pattern.
During this program, we will illustrate some of the benefits and drawbacks that may arise from these regulations, and provide you with practical considerations that will help you navigate the decision as to whether to make an election to apply the global intangible low-taxed income (GILTI) high-tax exclusion. We will discuss:
- Key considerations when deciding to make the election to apply the GILTI high-tax exclusion
- Who is most likely to benefit from making this election
- Main reasons to not elect to apply the GILTI high-tax exclusion
- Traps for the unwary in the proposed subpart F high-tax exclusion regulations
Original source can be found here.