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Daily Tax Report: International

Trade Groups Pressure Mnuchin on Global Minimum Tax Exclusion

July 23, 2019, 4:24 PM

Trade groups are pushing Treasury to issue rules that would ensure companies paying a high global tax rate can be shielded from a new tax on foreign income.

The Internal Revenue Service issued proposed rules (REG-101828-19) in June that would allow companies to elect out of the tax overhaul’s levy on global intangible low-taxed income (GILTI) if they are paying foreign taxes of at least 18.9%.Treasury should issue regulations that limit the allocation of domestic expenses to GILTI in situations where it would result in excess foreign tax credits, the groups said in a July 23...

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