IRS PLR: Extension of Time Granted to File GILTI High-Tax Exclusion Election in Late-Filed Amended Return (IRC §951A)

Domestic corporation (X) granted extension of time under Treas. Reg. §301.9100-3 to file a global intangible low-taxed income (GILTI) high-tax exclusion election (GILTI HTE Election) under Reg. §1.951A-2(c)(7)(viii) with respect to CFC, X’s controlled foreign corporation, for the CFC inclusion year that ends with or within X’s U.S. shareholder inclusion year (as defined in Reg. §1.951A-1(f)(7)), the IRS ruled. During the preparation of X’s Form 1120, U.S. Corporation Income Tax Return, X’s accounting firm informed X of the availability and benefit of making a GILTI HTE Election on an amended return, the IRS stated. Before the 24-month ...