IRS to Bifurcate Proposed Rules Under New Foreign Income Tax

The Internal Revenue Service is “likely to sever” rules under a proposed package related to a new category of foreign income and the aggregate treatment of U.S. partnerships, an IRS official said.

• The two sets of guidance could come out separately when they’re made final because they’re “not intrinsically linked,” said Daniel M. McCall, the deputy associate chief counsel (International) at the Internal Revenue Service.
• Proposed regulations (REG-101828-19) issued June 14 include guidance under tax code Section 958 for determining stock ownership and a high-tax exclusion under Section 951 on the global intangible low-taxed income, which would allow ...