IRS PLR: Extension Granted to Make GILTI HTE Election (IRC §951A)

The IRS has published a private letter ruling on I.R.C. §951A, and Treas. Reg. §§1.951A-2 and 301.9100, granting 120-day extension to file a global intangible low-taxed income high-tax exclusion (GILTI HTE) election for each controlled foreign corporation (CFC) in the taxpayer’s group. [PLR 202547013]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.